Transfer pricing documentation

There is a tendency for laws governing the obligation to have complete and up-to-date transfer pricing documentation, complete with benchmark studies (or a description of transaction compliance if no reliable benchmarks are available) to become progressively stricter over the years. Our support in all aspects of transactions with related parties includes:

• identifying transactions subject to TP documentation requirements,
• preparing both local and group (so-called master file) documentation,
• verifying the completeness of TP documentation prepared internally,
• benchmark studies or compliance descriptions which confirm that the prices of related party transactions are arm’s-length – both based on internal data supplied by the client and using external databases,
• preparing applications for advance pricing agreements (APA) and supporting clients in APA proceedings,
• help in meeting reporting obligations (e.g. TPR-C, CbCR),
• providing comprehensive support at every stage of tax proceedings.