Transfer Pricing policy
Planning and development; TP methodology for permanent establishments
Value chain analysis and transformation
Analysis and transformation of operational model, transfer of functions, risks and assets abroad; structuring of operational activities
Advance Pricing Agreements (APA)
Supporting during the process of negotiations and preparing the APA
Transfer Pricing advice
Advice on different TP matters
Development and implementation of Transfer Pricing business processes
Reporting and compliance
Assisting with preparation of three-tiered TP documentation (Countryby-Country reporting, Master file and Local file), notification of participation in Multinational Enterprise Group, report on controlled transaction
Transfer Pricing audits and disputes
Helping our clients defend position during TP audits and win TP disputes in courts
Business purpose and economic benefit test
Assisting in substantiation the economic benefit of intragroup services and intangible assets received
