We advise corporate customers in the development of principles for determination of the market value of transfer prices with the aim of hedging the customer’s tax risks.
We protect the customer’s interest and defend the customer’s position in tax disputes with both the local and foreign tax authorities. We provide assistance in the preparation and review of the transfer pricing documentation with the aim of ensuring compliance with the valid requirements.
- Analysis of and consulting on tax risks inherent in related party transactions
- Appropriate documentation on transfer pricing
- Analyses of comparative data
- Updating of comparative data
- Development of an appropriate price policy for related party transactions in accordance with the customer’s needs
- Drafting of contracts between related parties
- Assistance in the review of transfer prices
The significance of transfer pricing is growing in all EU Member States, with a majority of the Member States establishing new national regulations in the field. The specific rules vary by countries, but the background is the same – the OECD transfer pricing guidelines. The OECD guidelines have recently been significantly amended and will continue to be amended in the future, thus exerting pressure on the amendment of the local legal acts and administrative practice.
The economic decline has made transfer pricing even more important for international as well as local groups. With the tax authorities all over the world making an effort to stabilize the drop in tax revenues, audits of related party transaction pricing are becoming more frequent and increasingly aggressive, as evidenced in the Estonian practice in recent years. All aspects in the transfer pricing strategy must thus be carefully planned and regularly documented. The Estonian example shows that, in addition to transactions with major groups, the parties need to demonstrate (including to document) the compliance of the cost of all related party transactions with the market value. We must recognize that an efficient transfer pricing strategy involves all of the company’s business activities – i.e. addresses various aspects related to the compliance of the price of products, services, financing and intangible assets with the market value.
Grant Thornton continues to develop its international transfer pricing services and cooperation with other specialists in the network with the aim of coordinating the advice on transfer pricing and preparing the appropriate documentation.
We assist our customers in communication with the tax authority within the framework of tax audits. Furthermore, our transfer pricing specialists help the customer to create more tax-efficient and less risky transaction structures. We also provide legal advice, helping our customers to better adapt to the requirements of the local legal acts.
The Grant Thornton transfer pricing project involves tax advisers as well as legal advisers in symbiosis with financial advisers, engaging the offices of other countries, where necessary, to help the customer to control the risks related to transfer pricing, and exploit all opportunities provided by the taxation and legal framework.