Transfer pricing
Transfer pricing rules are very dynamic and affect a wide range of businesses. Whether you are a domestic or foreign related party, you are required to comply with the arm’s length principle when setting prices and conditions amongst associated enterprises. At the same time, related parties are obliged to prepare a transfer pricing documentation. In this respect, the individual tax risks must be identified correctly. In order to prevent the misconduct in various tax periods, it is important to keep the documentation on an ongoing basis.
Our services are tailored to assist you with the complex transfer pricing rules, from the beginning of business relationships to the fulfillment of individual obligations arising from transfer pricing.
As the transfer pricing is not detached from your business, it is necessary to properly identify the related parties and to assess possible transfer pricing implications when planning business activities. In our services, we offer a unique connection of legal and transfer pricing perspective. When preparing contracts, recommendations and opinions, we always consider both legal and tax contexts to avoid tax risks in your business. We know that good contracts are the basis for good transfer pricing.
In the area of transfer pricing, we will be pleased to offer you the following services:
- preparation of the argumentation for setting transfer prices in line with the latest developments at OECD / EU level, the European Court of Justice and the EU Joint Transfer Pricing Forum, etc.;
- identification of related parties (associated enterprises);
- consultations, expert support and preparation of the transfer pricing documentation itself;
- review of the transfer pricing documentation according to the requirements of the Slovak legislation (e.g. consideration of the Master file or Benchmark developed abroad);
- processing, evaluation and application of comparability analysis (Benchmark analysis);
- preparation of opinions and recommendations aimed at identification and elimination of transfer pricing risks;
- representation in transfer pricing proceedings (including the Advanced Pricing Arrangements, the Mutual Agreement Procedures and corresponding adjustments of the tax base);
- participation in tax inspections on transfer pricing;
- representation in tax proceedings and in the subsequent court proceedings on transfer pricing issues.