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TAX. ACCOUNTING. FINANCE. WHERE ARE YOU GOING?
"we deliver financial excellence"

TRANSFER PRICING

The highly dynamic global business environment and increasing pressure from tax authorities to generate tax revenues from all sources, put transfer pricing on the top of tax and finance issues today. We help our clients to have better understanding of transfer pricing and prepare full pack of transfer pricing documentation in line with local regulations. Our work is based on OECD Guidelines for transfer pricing, Corporate Income Tax Law as well as Rulebook on transfer pricing. Our approach to transfer pricing:

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YOUR NEEDS

  1. You need to have accurate and most optimized tax effects in a line with transfer pricing regulations
  2. You want to prepare perfect transfer pricing study or benchmark analysis
  3. You want to meet required deadlines
  4. You want to be sure that you have appropriate intercompany agreements and management fee policy
  5. You wish adequate fee for the consultancy service
 

OUR RESPONSE

  1. With advanced approach we will calculate best solutions and give appropriate advices
  2. Preparation of the most efficient transfer pricing study in a line with Serbian Laws and OECD Guidelines. Preparation of reliable benchmark study using most appropriate database
  3. Alerting of all tax return and documentation deadlines
  4. Advices and preparation agreements with related party and evidence for management fee services
  5. Offering a fee that meets your expectations

SERVICES

  • Preparation of transfer pricing study
  • Benchmark studies and other analysis
  • Advices in pricing policy with related parties
  • Preparation intercompany agreements
  • Management fee advisory
  • Dealing with tax authorities

2.strana

 ASK YOUR QUESTION

REQUEST FOR OUR OFFER
In your request please give short information about your transactions with related parties:

  • Kind of transactions
  • Amounts of transactions
  • Information about loans and interest rates
  • Information of management and royalty fees
  • Existence of TP master file

2.stranaa"Both tax administrations and taxpayers often have difficulty in obtaining adequate information to apply the arm's length principle.

Because the arm's length principle usually requires taxpayers and tax administrations to evaluate uncontrolled transactions and the business activities of independent enterprises, and to compare these with the transactions and activities of associated enterprises, it can demand a substantial amount of data.

The information that is accessible may be incomplete and difficult to interpret; other information, if it exists, may be difficult to obtain for reasons of its geographical location or that of the parties from whom it may have to be acquired. In addition, it may not be possible to obtain information from independent enterprises because of confidentiality concerns.

In other cases information about an independent enterprise which could be relevant may simply not exist, or there may be no comparable independent enterprises, e.g. if that industry has reached a high level of vertical integration.

It is important not to lose sight of the objective to find a reasonable estimate of an arm's length outcome based on reliable information. It should also be recalled at this point that transfer pricing is not an exact science but does require the exercise of judgment on the part of both the tax administration and taxpayer".