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Identification of risks of transfer pricing

Identification of risks of transfer pricing

Our experts will help You identify existing risks, to build an optimal structure of control over market prices and to take care of all the problems associated with communication with the tax authorities on the issue of controlled transactions.

Due to the fact that in the normative regulation of the norms of transfer pricing still remains a lot of legal gaps and inaccuracies, the interpretation of many rules is based only on the letters of the Ministry of Finance and state fiscal service of Ukraine. But, despite the large number of such recommendations, many questions remain unsolved, in addition, some of the letters contradict each other. To help in the interpretation of the norms of transfer pricing cannot and jurisprudence – at the moment it is not yet formed.

Thus, at the moment transfer pricing is one of the most risky institutions of tax law from the point of view of additional tax assessments the tax authorities, because the more gaps and discrepancies in the legislation, the more difficult the procedure of pricing, the greater the probability that the tax inspector and the taxpayer will be a different interpretation of the same norm. Meanwhile, the penalties for violating the rules of transfer pricing are currently the largest in the tax law.

We work at your forms and queries in a convenient format, for example:

  • analysis of individual contracts and transactions between the interdependent persons;
  • analysis and adjustment of the system of control over transfer pricing for the whole company;
  • guidelines on validation of counterparties for risk avoidance transfer pricing;
  • analysis and modification of the structure of relations between related parties to minimize the risks of transfer pricing;
  • advice on specific issues of tax law in the TP.

We work with Ukrainian enterprises and their foreign elements. We can help You to make the documentation about market prices and to confirm it, to accompany the test of transfer pricing or defend Your interests in court.