Transfer pricing is said to be an art, not a science. We believe that it takes both science and art to make transfer pricing a useful tool in your company and not an issue.
The transfer pricing file is the main tool that can be used by a group of companies to prove that the intra-group transactions are performed at arm’s length. During the last years, the transfer pricing file has become one of the main topics during the tax audits of the Romanian tax authorities.
Our transfer pricing services include the following:
Planning and implementation stage for transfer pricing:
- Assistance in developing and implementing transfer pricing policies for new intra-group transactions;
- Assistance in the preparation of Advance Pricing Agreements and in the negotiations with tax authorities;
- Assistance in analyzing the local transfer pricing impact of potential group business restructuring;
- Assistance in performing benchmark studies for new transactions;
- Transfer pricing analysis of new agreements for intra-group transactions.
Transfer pricing documentation stage:
- Preparation of the transfer pricing file, in accordance with Romanian and OECD transfer pricing guidelines (including BEPS actions);
- Preparation of sections of the transfer pricing file (e.g., economic analysis, including benchmark studies);
- Review of the Masterfile from a Romanian perspective and adaptation of the documentation available at group level based on the Romanian specific requirements;
- Review of existing transfer pricing documentation;
- Assessment of potential transfer pricing risks of existing intra-group transactions.
Transfer pricing audit stage:
- Assistance during the discussions with the tax authorities (including regarding the transfer pricing policy applied during the audited period);
- Assistance in the preparation of various documents specific to the tax audit process (e.g., answers to various requests of the tax inspectors, preparation of the point of view);
- Tax litigation assistance (e.g., preparation of a tax appeal).
Other transfer pricing services:
- Trainings on transfer pricing matters for key personnel in your company.