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Transfer Pricing

Transfer pricing services

Transfer pricing controversy

  • Management of transfer pricing inspections
  • Transfer pricing dispute resolution 

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Transfer pricing due diligence

  • Risks assessment focus on intercompany transactions/transfer pricing models
  • Identification of gaps between the transfer pricing policy and the actual implementation of the transfer pricing policy/model.

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Transfer pricing documentation

  • Preparation of CbCR
  • Assistance on the CbCR notification to the Slovak Tax Administration
  • Preparation of Master File
  • Preparation of Local File
  • Preparation of benchmarking studies (visualization tool – transfer pricing analytics)
  • Globally coordinated transfer pricing documentation - PwC’s Global Coordinated Documentation™ (GCD)

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Transfer pricing planning and implementation

  • Design/redesign of intercompany transactions in order to align them with the arm´s length principle
  • Alignment of TP polices within the Group
  • Preparation of internal TP Guidelines/Directive
  • Alignment of IT tools with TP reports

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Advance Pricing Agreements (“APAs”/ Mutual Agreement Procedures (“MAPs”) assistance

  • Preparation of the petition
  • Assistance during the APA/MAP process

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In-house training for transfer pricing teams

  • Transfer pricing basics
  • Transfer pricing advance
  • Customized trainings based on the company´s requirements

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Transfer Pricing
Perspectives - The new normal:
full TransParency


The articles in this October 2016 edition of Transfer Pricing Perspectives are based on our sessions at our recent Global Transfer Pricing Conference in Toronto. For this year’s edition, we would like to highlight new and refined service offerings, such as value chain analysis, that are best suited to tackle the new challenges. Global Coordinated Documentation with the Master File and Local File, as well as country by country reporting have changed the perception and added to the complexity of TP compliance in a significant way. Finally, we continue to “bridge the gap” between tax and industry expertise, which is why we are happy to share several excerpts on industry developments as well. We hope you will enjoy reading and that they will help you be even better equipped for the changes we’re expecting to see in the coming.


Contact us

Bartosz  Jasiolek

Bartosz Jasiolek

Partner, Tax & Legal Leader, PwC Slovakia

Christiana Serugová

Christiana Serugová

CEE TLS Lead Relationship Partner, PwC Slovakia

Tel: +421 903 261 010

Alexandra Jašicová

Alexandra Jašicová

Senior Manager, PwC Slovakia

Tel: +421 903 243 561

Michaela Firická

Michaela Firická

Manager, PwC Slovakia

Tel: +421 911 010 531

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