Comply with the new Company Tax regulation referring to related party transactions.
Compile the necessary documentation and justify the prices applied among related party transactions.
Planning and structuring Transfer Price pricing for companies of the same Group (locally, regionally or globally).
Design transfer price policies in order to optimize the allotment of centralized expenses.
Preparation of the documents referring to the Country File and to the Master File.
Analyze operations and application of profits in order to determine normal market value.
Design transfer pricing policies relating to financial operations, such as:
Loans among related parties.
Granting of guarantees among related parties.
Agreement relating to cost distribution.
Analysis of compensations to remunerate activities of financial intermediation.
Analysis of contractual agreements under transfer pricing policies.
Assistance in proceedings with the Tax Authorities.
Benchmarking and determining market value of operations agreed in related party transactions.
Assistance provided by fiscal experts.
Our experience allows us to determine market value benchmarks such as: operations of tangible assets, rendering services to companies in different sectors, interest rates derived from cash-pooling; commissions, amongst others.