Transfer pricing

Transfer pricing services include the following:

  • Preparing the full scope transfer pricing documentation or updating the existing documentation
  • Preparing comparability (benchmarking) study, using local or international databases (Amadeus, RoyaltyStat)
  • Reviewing the cross-border transactions to verify their compliance with the arm’s length requirements
  • Transfer pricing training
  • Assistance in disputes with the State Revenue Service during a tax audit, appealing to the Director General of the State Revenue Service and representation in the court

For certain transactions with related parties there is no need to prepare full transfer pricing documentation due to high costs. In these cases, we propose preparing merely benchmarking analyses to determine the market profit level (e.g. for management and consulting services).