Transfer prices and taxcompliance

Preparation of transfer pricing documentation requires support. Our law office helps in preparation of transfer pricing documentation and benchmarking in accordance with the provisions of the Corporate Income Tax Act and the Personal Income Tax Act.

We offer support in negotiations with the Ministry of Finance. The obligation to keep tax documentation of transactions (transfer prices) rests with entities that exceed the statutory thresholds of value. But even if the statutory threshold is not exceeded, transactions between related parties should meet the arm’s length principle and be duly documented.

The taxcompliance service has a slightly different purpose and scope. This service includes all taxes and consists in checking whether the business and individual transactions comply with the provisions of the tax law. Starting from checking compliance with registration and reporting obligations to documentary duties, which in the context of the tax on goods and services is imposed by the doctrine of good faith. It is necessary to check whether the tax deductible expenses have been classified in accordance with the tax law or whether the withholding tax has been correctly settled. A tax audit is recommended within the taxcompliance service. It is worth verifying existing or planned business structures in terms of the general tax circumvention clause (GAAR) or the regulations on foreign controlled companies (CFC).