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Transfer pricing services

We assist our Clients in managing the transfer pricing risk in their business operations. We provide services to many international and domestic enterprises, developing and optimising transfer pricing policies for transactions in Armenia and co-ordinating several regional transfer pricing projects.

Scope of services

  • Tax planning and optimisation advice to establish and implement the appropriate transfer pricing methodology for international and domestic transactions
  • Providing recommendations for appropriate valuation of product flows, services and intangible assets in related-party transactions focusing, in particular, on the transfer pricing methodology selected
  • Analysis of the your business activities to identify major areas of transfer pricing exposure
  • Developing documentation to support the transfer pricing methodology adopted in inter-company transactions, including the development of a functional analysis (functions, assets and risks)
  • Benchmarking studies
  • Providing assistance during corporate tax audits and help in preparing defence documentation supporting the client’s position.

Transfer pricing planning

We advise clients in structuring their cross-border and domestic activities to develop and implement the optimal arrangements of activities. Once the new structure is determined, we assist the Client with implementation, in particular:

  • review of inter-company agreements and recommendations on the wording of fee clauses
  • review or preparation of transfer pricing documentation
  • preparation of benchmarking studies
  • preparation of conversion documentation supporting the change in the inter-company pricing and flows
  • developing a transfer pricing manual with guidelines concerning the calculation of transfer prices for their accounting and finance staff.

Transfer pricing review

We analyse inter-company agreements, transfer pricing statements and internal policies, invoices and supporting documents to highlight any transfer pricing exposure. Where appropriate, we recommend an alternative approach to the structuring of inter-company transactions.

Contact us

Hasmik Harutyunyan

Tax and Legal Services Leader

Tel: +374 (10) 51 21 66

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