Preparation of transfer pricing documentation i) Country by Country Reporting; ii) Masterfile documentation and iii) Local file documentation.
Review of the actual transfer pricing situation of the Group, detection of possible tax contingencies and recommendations and practical solutions designed to mitigate, as far as possible, those contingencies. This diagnostic services is especially relevant following the publication of the 15 Actions of the OECD BEPS project.
Design and implementation of transfer pricing policies consistent with the arm’s length principle. Assistance in the definition of conditions to apply in new related party transactions, as well as the support in implementation of thes new policies within the Group.
Determination of market references with the objective of establishing or justifying the remuneration agreed between group companies or otherwise related parties. Application of the methods contemplated in local legislations by way of complex and sophisticated economic analyses, where necessary. Application of required databases, both on a national level and international level.
Advisory and assistance in the preparation of information to be included in the Country by Country tax returns.
Assistance throughout the tax inspection process.
Preparation of all the documentation necessary for initiating an APA with the tax administration, as well as the assistance in the corresponding negotiation of proposed terms.
Revision of intercompany contracts and agreements from a transfer pricing perspective.
Training and courses in transfer pricing, designed specifically to the necessities of your team of professionals or finance department. Our customised training takes into account your market sector, as well as the company’s objectives.