Transactions within multinational companies are becoming increasingly important in business worldwide. All transactions among related parties are influenced by the Czech legal framework, which has recently become significantly stricter. For tax purposes, prices agreed between related parties have to meet the definition of arm’s length principle, and these prices are often subject to tax audits carried out by the Tax Authorities. The consequences of incorrect transfer pricing adjustments are tax exposure and penalties. In the case of companies receiving investment incentives, incorrect transfer pricing treatment can cause potential losses.
A specialized team of PwC tax professionals with expertise in both national and international tax law, combined with specific industry experience, can provide risk processing and benchmarking analyses enabling the determination of the prices for services and goods at arm’s length principle. We will help you to create a strategy and arrange the steps for transfer pricing and provide you with all documentation under the OECD directive.
- Assessment of your current transfer pricing procedures to highlight any risks
- Based on a detailed analysis of the company’s business situation and needs, we will review and create a customised transfer pricing strategy (proactive and reactive).
- Full review of existing group transfer pricing policies
- Preparation of an industry-specific benchmark analysis
- We will provide you with a detailed benchmarking analysis in your specific industry to enable us to determine the prices and profitability of goods and services that will adhere to arm’s-length principles.
- Assistance with the preparation of a new transfer pricing policy
- Assistance with the preparation and filing of the Advance Pricing Agreement (APA)
- According to the Income Taxes Act, it is possible to ask the Tax Authorities for an APA. We will assist you with the preparation and filing of the APA, including preparation of supporting documentation
- Comprehensive transformation of your existing business structure to a more tax and business-effective model
- Preparation of all required supporting documentation
- We will provide you with all the documentation required to fully comply with the guidelines as laid down by the OECD. This documentation is essential to prove that your transfer-pricing structure complies with all the current rules and regulations.
- Assistance with any negotiations with the Tax Authorities
- We can act on behalf of your company in the event of negotiations with the Tax Authorities and, potentially, assist with the preparation of documentation for a court claim.