Co-operation of equity or personally affiliated entities has for a long time constituted an object of tax bodies' particular attention. Improper construction of pay arising from agreements concluded between such entities means considerable risk of price evaluation due to a tax or fiscal inspection. Additionally, affiliated entities which perform transactions between each other are in most cases responsible for producing documentation of transfer prices.
Our experts, based on their experience gained over the long-term co-operation with domestic and international capital groups, help entrepreneurs limit the risk of particular transaction conditions being questioned by tax bodies.
The scope of services delivered by JP Weber in the area of transfer pricing entails actions including the following:
- Identification and analysis of transactions performed between affiliated entities;
- Determination of tax risks related to the method of establishing the transaction fee;
- Development, in close co-operation with the entrepreneur, of the transfer pricing policy entailing definition of rules for settlements between affiliated entities as well as selection and justification of methods for establishment of transfer pricing;
- Development of transfer pricing documentation fully compliant with requirements imposed by domestic tax regulations;
- Reviewing documentation made available to us by the entrepreneur in terms of potential tax risks as well as recommending solutions orientated towards minimising risks for particular agreements;
- Drawing up applications and maintaining proceedings orientated towards entering into settlements with regard to establishment of transfer pricing (Advanced Pricing Agreements, APA).