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The transfer pricing rules set five methods of determining the market price for determining the taxable income in the transactions which parties are interdependent persons:
When performing a single transaction, the market price may be determined by the results of the independent evaluation, but only if such a transaction is impossible to apply any of the methods listed.
The application of each of the methods is possible only in a strict sequence, that is, the tax law stipulates that each method (or group of methods) of determining the price shall apply if it is not possible to apply the previous one. Justification of the choice of the method and its implementation requires high qualification and sufficient experience of working with transfer pricing legislation, and specific information of equipment, access to databases. This is a joint work of economists and lawyers.
To determine the proper and most beneficial to the client methodology for determining the market price, and to prepare a rationale for selecting the method for its determination will help our specialists. We work with the features of Your business, its assets and functional relationships between companies. Technology requests and analysis of information has been developed by us specifically to implement this type of service. If necessary we will also arrange a valuation of assets by professional valuers our partners.
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