Examination and documentation of transactions between related entities (TP)
Our law firm's tax advisors have extensive and long-standing experience in preparing transfer pricing (TP) documentation. Our services in this area include:
Transaction analysis between group entities Before tax documentation is prepared, we work with you to determine the scope of the documentation. In addition to obvious transactions such as goods, services, and loans, we also examine the occurrence of less typical financial transactions (guarantees, warranties) or other events (partnership agreements, restructurings). Only after thoroughly identifying the scope of the documentation obligation, such as exemptions from tax documentation, can the tax obligation in this area be properly fulfilled.
Preparation of local transfer pricing documentation – the so-called Local File Possession of the Local File is mandatory for taxpayers conducting transactions with related entities when statutory limits are exceeded and no conditions for exemption from this obligation apply.
Preparation of a comparative analysis – the so-called Benchmark An obligatory element of the local transfer pricing documentation is the Benchmark, or comparative analysis for a given transaction. Preparing a correct Benchmark requires meeting a number of statutory conditions, and it is a key part of transfer pricing documentation. We prepare Benchmarks tailored to the individual requirements of clients.
Preparation of the TPR report One of the obligations arising from transfer pricing regulations is the submission of the annual TPR report to the tax authorities. This report requires knowledge of both the taxpayer's transactions and how to complete the TPR form. It is often preceded by an analysis of the taxpayer's TP obligations. Correct completion of the report is important, as it is the first source of information for the tax authorities about the taxpayer.
Analysis of new transactions and preparation of agreements from a tax perspective As important as preparing transfer pricing documentation for existing transactions is the proper structuring of new agreements and transactions. Our law firm assists in preparing new agreements with related entities to safeguard against tax risks, including transfer pricing issues.
Support for taxpayers during transfer pricing audits Currently, tax authorities scrutinize related-party transactions during tax audits. The expert assistance of our tax advisors during audits effectively helps to ensure a favorable outcome for our clients in the verification process by the tax authorities.