Transfer prices represent the prices at which products are sold to related parties or at which services are performed between related parties.
A person related to a taxpayer (within the meaning of the Corporate Income Tax Law) is considered to be a natural person in whose relations with the taxpayer there is a possibility of control or significant influence on business decisions. In the case of indirect or direct ownership of at least 25% of shares or stakes, it is considered that there is a possibility of control over the taxpayer.
Transfer prices also include the granting of mutual loans or credits.
MicroFinance Consulting offers you the PREPARATION OF TRANSFER PRICING REPORTS (TRANSFER PRICING STUDY) in accordance with applicable legislation, OECD guidelines for the application of transfer pricing rules, the Transfer Pricing Regulations and methods that are applied according to the "arm's length" principle when determining transaction prices between related parties.
Along with the tax balance, the taxpayer is required to submit a transfer pricing study (Transfer Pricing Report), if he had transactions with related parties. The documentation is the basis that contains the argumentation necessary for the analysis of transfer prices and their compliance with the "arm's length" principle.
The transfer pricing study (Transfer Pricing Study) must be submitted within the legally prescribed deadline, which for legal entities is 180 days from the end of the tax period (June 30) and for entrepreneurs, March 15 of the following year.
A transfer pricing study (Transfer Pricing Study) may contain:
1. Analysis of the group of related legal entities to which the taxpayer belongs
2. Analysis of the activity
3. Functional analysis
4. Selection of methods for verifying the compliance of transfer prices with prices determined at arm's length
5. Analysis via a database of a software package specialized in transfer pricing
6. Explanation of transfer pricing transactions in the tax audit procedure
7. Depending on the business of the company and the types of transactions that have occurred between related parties,
MicroFinance Consulting can perform the following for your company:
1. Preparation of a summary report on transfer pricing ( Preparation of a summary study on transfer pricing )
2. Preparation of a transfer pricing report (Preparation of a transfer pricing study) in full form
For all information regarding the preparation of transfer pricing studies, you can call us or send us an email, which you can see on our "Contact" page.
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