Transfer Pricing Policy and Planning

Benchmarking study

Multinationals face heightened interest in their tax and transfer pricing positions. There is an old saying that the best defense is a good offense. In the transfer pricing world, the best way to safeguard against potential transfer pricing challenges is to set up a proper transfer pricing policy in advance of commencing related party transactions.

To safeguard against potential transfer pricing challenges and double taxation, implementing a proper transfer pricing policy is crucial to proactively ensure consistency of your arrangements with the arm’s length principle and protects against potential challenges and double taxation.

We can assist you with setting a policy for a specific intercompany transaction, a newly established entity or for the whole group.

Our services:

  • Crafting a supportable transfer pricing policy that will support the group’s operations in a tax sustainable way
  • Evaluating existing transfer pricing policies for risks, and providing pragmatic corrective solutions, keeping in mind your global business and tax strategies
  • Drafting intercompany agreements that reflect your transfer pricing policy by legal and transfer pricing experts
  • Providing support in the implementation of your transfer pricing policies with operational matters, processes and data preparation;
  • Assistance in complex transfer pricing planning including around business restructurings and value chain transformation, as well as intellectual property planning
transfer pricing documentation
transfer pricing documentation

Benefits:

  • Enhanced compliance with transfer pricing rules, enhanced corporate governance and TP risk management
  • Reduced tax costs by mitigating the risk of double taxation
  • Better insights into the results of each business segment/entity, with appropriate allocation of shared resource costs to individual group affiliates.
  • Sustainable platform for intra-group cooperation and business expansion
  • Ensuring sufficient financing for operational (routine) entities
  • Simplified transfer pricing compliance

Contact us

Dragan Draca

Dragan Draca

Partner, Tax Services, PwC Serbia

Mirjana Petkov

Mirjana Petkov

Director, Transfer Pricing Services, PwC Serbia

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