Employees are the greatest asset of any company, upon which competitive advantage is built - but they are also one of the largest cost factors. Every business leader should think about on whether we are doing all we can, to preserve this investment and whether we are making the most of our employees' potential.
Grant Thornton Baltic OÜ advised German company RAUMEDIC AG on the acquisition of aktsiaselts A&G. RAUMEDIC AG is a leading developer and manufacturer of systems and components and a partner to medical and pharmaceutical industries. Core business of aktsiaselts A&G is production of medical supplies.
From 2022, an updated regulation will take effect, regarding the methodology for determining transactions between related persons. Since it was adopted in 2006, Minister of Finance regulation no. 53 had been in force unchanged.
The Danish tax authority increased the taxable income of Tetra Pak Processing Systems A/S due to shortcomings in transfer pricing documentation and continuous losses. The Danish Supreme Court reached the conclusion that the transfer pricing documentation filed by the company did not meet the requirements as the documentation lacked a competent comparability analysis.
The OECD (Organisation for Economic Co-operation and Development) regularly updates its 2017 transfer pricing guidance. It is worth keeping up to date with the OECD guidelines because transfer pricing regulations in Estonia and many other countries rely on the OECD’s guidelines.
In the case of the Finnish tax authorities and A Oy, we can see how incompetent preparation of transfer pricing documentation can create a large administrative burden for the company. Although the case ended in A Oy's favor, they had to spend time and money to have the decision of the Finnish tax authorities to adjust the taxpayer's transfer prices and add additional income tax on the adjusted profits annulled.
The restrictions established due to the COVID-19 pandemic have disrupted transfer pricing within international corporations. Even if the restrictions were to be eased, undertakings would face major uncertainty about risks and comparables for determining market value.