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PwC Slovenia provides a full range of corporate taxation services. Our specialist teams provide customized solutions for your specific individual needs and objectives, while keeping you informed of relevant changes in the tax and legal landscape. This allows us to maximize your cost effectiveness and manage your compliance in the face of changing regulations.
Additionally, to our opinions on your specific inquiries, our corporate income tax specialists will review your corporate income tax returns. The compliance review may be performed as a top-line compliance review or an in-depth analysis, depending on your needs. Top-line compliance reviews are especially recommendable if performed on a regular basis through a longer period, while in-depth analysis is usually required upon significant changes of tax legislation. Compliance reviews may relate to an entire selected tax period or part of it.
The PwC Slovenia Compliance Department offers the following services within the corporate tax field:
Our support helps create an easier and more efficient compliance life for our clients. In addition, we support our consultant teams in all compliance-related matters.
If you have any challenges or questions in connection with your tax returns, assessments or correspondence with the tax authorities - let us know.
Transfer prices significantly affect the entire business chain of companies; from research and development, production, marketing, to distribution and sales as well as after-sales activities. As a general rule, all international companies regularly face the challenges arising with the complex and rapidly developing area of transfer pricing. When a transfer pricing concern arises in a business model, substantial savings and profits are in question.
At PwC Slovenia we are aware of the importance of transfer pricing, and, being part of a global network, we offer your business our vast international experience to produce optimal results for your business at optimal value. Our experts will advise you on the strategy and methodology of setting transfer prices as well as assist with the documentation on transfer prices, compliant with Slovene legislation.
In the area of transfer pricing, Slovenian tax legislation is coordinated with the OECD guidelines for determining transfer pricing for international companies and tax administrations. The current legislation also determines which transfer pricing documentation the taxpayer must keep and submit to the tax authority in the event of a tax audit.
Purpose of the Transfer Pricing documentation is to defend the compliance with the arm's length principle. Arm's length principle refers to transactions between related parties that should be valued as if they had been carried out between unrelated parties, each acting in their own best interest.
The transfer pricing documentation must therefore be designed in such a way that, in the event of a tax inspection, compliance with the arm's length principle will be properly presented and substantiated.
PwC Slovenia’s experienced consultants can help you create documentation in the field of transfer pricing, thereby reducing the risk of unforeseen additional tax obligations related to transfer pricing.
Advance Pricing Arrangements (APAs), which are often used as a useful strategy to resolve disputes with the ATO and/or as a preventative approach where audit risk may otherwise create uncertainties. Such an agreement for a predetermined fixed period reduces the risk of unpredictable tax inspections.
With our help you can:
As a result of the taxpayer’s failure to provide documentary evidence on transfer pricing to the Slovenian tax authorities, penalties of up to EUR 30.000 may be imposed. Other adjustments (increases) of tax base and penalties are also possible.
This shows the vital importance of effective and efficient documenting and benchmarking of intra-group transfer pricing policies and practices, for organizations seeking to protect themselves from revenue authority scrutiny and from potential financial consequences.
According to a Global transfer pricing survey, transfer pricing represents the most significant international tax issue facing companies with international exposure. This is further confirmed by the following facts:
A penalty was actually imposed in half of the cases in which it was threatened
An increasing number of countries are implementing laws regarding the preparation of transfer pricing documentation. PwC Slovenia is able to help you to prepare consistent documentation for all types of inter-company transactions in compliance with local regulations.
A combination of international exposure and multiple documentation requirements mean that corporations must prepare local transfer pricing documentation in every single country in which they operate. This is particularly the case in Slovenia with stringent regulations governed by Article 382 of the Slovenian tax procedure act (ZDavP-2). In this context, we can assist you to:
Global Coordinated Documentation® approach assists clients in managing transfer pricing documentation cost-efficiently by creating local documentation based on global common data and information.
At PwC Slovenia we utilised our extensive international network of transfer pricing experts to create a Global Core Documentation® scheme.
This scheme can be tailored to suit your needs and requirements. The first step in the process is the prioritization, analysis and formation of a core file of documents. It consists of group-wide information, applicable to all countries (e.g. Master File). In the second phase, local economic analysis and presentation may be added to form a local report (e.g. Local File). Distinguishing core from local is a dynamic process and corresponds to your specific needs, along with the risks your operation might be facing. In this respect, it reflects both the operational and tax objectives of the business.
|Step 1||Step 2||Step 3|
Create a joint global and local team (at PwC Slovenia) to fit your needs
Map related-party transactions of identified pilots
Complete Global Core Documentation
Assess risks and opportunities
Analyse global and local operations, financial situation and corporate legal structure
Establish scope of activities and work (countries, regions, pilots)
Define common platform of inter-company dealings
Local country documentation reports (roll-out)
Project planning and designing a timetable
Ensure consistency among different counties
We can design and implement tax efficient business models by combining and integrating the concepts of value-based management, market and customer management, supply-chain management, transaction processing efficiencies, integrated systems and optimal tax structures in an international environment.
We can optimize the efficiency of your intellectual property from a tax perspective enabling you to monitor profits, structure your intellectual property effectively and create intellectual property transfer pricing policies. According to Slovenian legislation, the tax authorities can require the taxpayer to produce supporting documentation in order to determine the true nature of transactions and whether unjustifiable profit monitoring has occurred. In this context, taxpayers also have the responsibility to justify the deductibility of their business expenses. Some of the risks we can help you reduce:
At PwC Slovenia we adhere to the highest standards and ensure our clients' satisfaction. In this context, preparing a local or global documentation set allows you to manage your transfer pricing documentation in the optimum way. Implementing our documentation techniques allows you to:
Regardless of the size of your organization or the sector of your business operations, establishing an appropriate corporate structure is essential to minimize tax and operational costs. Organizations can grow organically or by expanding through mergers and acquisitions. However, to maintain a sustainable growth your company will need foresight and expertise. PwC Slovenia has established an experienced multi-disciplinary and dedicated team of experts who specialize in tax and corporate law. We can help you to perform mergers and acquisitions activity in a tax-effective manner and to devise an efficient tax-structuring strategy to reduce your overall tax liability.
We will support you in building strategic growth of your company by providing credible advice on tax effective mergers and acquisitions in the light of Slovenian and EU tax and corporate regulations. We ensure that the legal structure of your business and sales operations is geared towards providing you with the utmost benefits. We will help you draft contracts and other tax requirements to ensure that tax efficiency is fully integrated into the way you do business.
Tax structuring and mergers and acquisitions demand a multidisciplined approach of taxes, finance and law in order to provide you with comprehensive advice in all aspects of your national or international business operations. The net result of our performance will show in increased shareholder value.
PwC Slovenia can help you:
We provide tax advice on all real estate issues from the straightforward to the highly complex including:
More complex issues require involving a combination of interdisciplinary real estate, tax, legal and financial expertise. Such high-profile work includes the following services:
· Domestic and international tax structuring, including advice on:
o Beneficial holding location
o Setting up company structures
o Development issues
o Exit strategies etc.
· Mergers and acquisitions, along with post-deal restructuring, including due diligence for both acquisitions and disposals
· Setting up of real estate fund in various tax jurisdictions through PwC Global Network
· Value Added Tax and transfer tax optimization
· Providing advice on utilization of investment tax credits and optimization of capital gains
· Buy side and supply side Real Estate Deal Support services – REDS
We are able to draw on the expertise of our international real estate network to ensure that both international and home country requirements of the investor are addressed on a seamless basis.
Mojca Bartol Lesar
Partner, Tax and Legal Services Leader, PwC Slovenia
Tel: +386 31 790 584