Transfer pricing represents the assessment of the economic relationship between related parties. It is based on international legislation where the basic legislative framework is laid down in the 2010 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations as well as the requirements of the national legislation contained in the Income Tax Act.

In the case of a tax audit, the tax authority requires proof of “comparability” with market prices between independent parties, leading to the necessity of preparing transfer pricing documentation with the identification of a suitable valuation method for transactions between related parties.

in this context, our company offers:

  • Preparation of documentation on transfer pricing (master file, local file, expert evaluation)
  • Assessment of already prepared documentation from abroad (e.g. from the parent company) and preparation of local documentation (for the needs of the subsidiary)
  • Updating of documentation on transfer pricing
  • Setting up the correct system for accounting for transfer prices
  • Preparation of internal directives on transfer pricing
  • Consultation on transfer pricing

As part of the transfer pricing documentation, we perform functional and risk analysis that identifies the economically significant features of the transaction, analysis of the risks in relation to the nature of the transaction under consideration and the assets associated with the transaction. We then determine the most appropriate methods for determining the usual (arm’s length) price and perform a comparative analysis of the arm’s length price.

Transfer pricing documentation contains conclusions for tax purposes, so in connection with its submission during a tax inspection we also provide our clients with additional consulting services to clarify the methods of determining the arm’s-length price and the conclusions of our analysis to the relevant tax administrator.