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.

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Insight The nine steps for determining transfer pricing

Marko Rebane, Legal and Financial Manager

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