Transfer Pricing
Our Services
- Preparation of transfer pricing documentation and benchmarking studies
- Preparation of the transfer methodology/policy
- Representation in tax disputes with the Tax Authority
- Preparation of Country-by-Country report
- Preparation of advance pricing agreements with the Tax Authority
Preparation of transfer pricing documentation and benchmarking studies
Lithuanian companies with an annual turnover of over EUR 3 million must prepare the transfer pricing documentation
We prepare transfer pricing documentation and benchmarking studies for various inter-company transactions between associated parties
Based on your needs, we can prepare the transfer pricing documentation in comply with foreign country‘s transfer pricing requirements and practice
Preparation of the transfer methodology/policy
We prepare transfer pricing methodology/policy to determine the arm‘s length pricing
Representation in tax disputes with the Tax Authority
We consult and represent taxpayers at all stages of tax-related disputes
We prepare responses/explanations to tax administrator’s requests
We participate in meetings and negotiations or help to prepare for meetings and negotiations with the tax administrator
Preparation of Country-by-Country report
Multinational (MNE) groups of companies with a consolidated group annual turnover of over EUR 750 million in a financial year, are required to submit a yearly Country-by-Country Report (CbCr) to the Tax Authority. The County-by-Country Report should include the net turnover earned from related and third parties in every tax jurisdiction, corporate income tax paid (including withholding tax), stated capital, number of employees and other information.
PwC’s specialists can help:
To prepare a CbC report notification to the Tax Authority
To assist in preparing a CbC report
- To assess transfer pricing risks by using a number of financial ratios
Preparation of advance pricing agreements with the Tax Authority
We help to prepare an application for advance pricing agreement (APA) with the Lithuanian Tax Authority on the applicable principles of the transfer pricing. Benefits of advance pricing agreement:
- It is extremely useful for companies that are going to conclude a complex controlled transaction for which it is difficult to find a comparative data;
- It helps to reduce transfer pricing risks for a 5-year period;
- It minimizes the costs of preparing the transfer pricing documentation.
Professional team
PwC has been offering the transfer pricing services in Lithuania for over 10 years. The transfer pricing team in Lithuania consists of about 10 specialists, who have accumulated extensive experience and can help you to implement the most complex projects.
Cooperation with the Tax Authority
PwC constantly cooperates with the Lithuanian tax administrator and participates in tax disputes. This experience enables us to provide high quality PwC’s services and offers solutions to clients in accordance to the latest trends in the tax administrator’s practice.
Specific Transaction Analysis
We have many years of extensive experience in implementing complex projects that require high qualifications, experience and specific databases or tools, for instance by determining the pricing of financing, licensing, patent sales and other transactions.
Databases
Our internal (TP-AI CUT) and external (e.g. Amadeys, TP Catalyst, DealScan, RiskCalc) databases provide access to the financial information we use to prepare benchmarking studies for various transactions.
Internal tools
We use internal tools (e.g. GCD reporter, CbC Analyzer), which contribute to the rapid and efficient analysis of information and preparation of transfer pricing documentation.
