TRANSFER PRICING
Transfer pricing?
Whether you need preparation of transfer pricing documentation, benchmarking analyses, or advice on transfer pricing matters, don’t hesitate to contact us.
Transfer pricing is the process of setting prices for transactions between related parties or companies within multinational groups. It applies to all businesses that trade with foreign subsidiaries, branches, or other affiliated entities. Properly established transfer prices are crucial for complying with tax regulations, preventing double taxation, and eliminating the risk of penalties from tax authorities.
At ETL, we focus on providing comprehensive solutions in the area of transfer pricing, helping businesses not only meet legislative requirements but also optimize their tax burden. We relieve you of the complexities of tax and regulatory obligations related to transfer pricing so you can concentrate on what you do best – managing your business.
When you partner with us, you can be confident that your transfer pricing matters are handled by experienced professionals who have your business goals in mind. We work closely with you to understand the specifics of your operations and develop transfer pricing strategies that comply with both local and international regulations.
International Collaboration for Global Solutions
ETL Slovakia and ETL GLOBAL are structured to meet the needs of businesses in all sectors – from manufacturing and trade to services. Thanks to our global network and collaboration with international partners, we are able to provide specialized transfer pricing consultancy with worldwide reach. This means we can ensure consistency and compliance with transfer prices in all jurisdictions where you operate.
Our services include:
- Preparation of transfer pricing documentation according to local and international standards (OECD guidelines, BEPS Action Plan).
- Benchmarking analyses to determine market prices between related parties.
- Advisory on setting transfer prices and internal company policies.
- Support during tax audits and defense of transfer pricing before tax authorities.
- Training and workshops for your teams in the area of transfer pricing.
- Coordination of international projects in cooperation with our foreign offices.
Procedure
Our services
Master File and Local File Documentation
Compliance for transfer pricing purposes according to the OECD Guidelines and the specific requirements of the respective jurisdiction.
Country by Country
Elaboration of Country by Country reports.
Benchmarking Studies and Comparability Analysis
Benchmarking and comparability studies according OECD Guidelines in compliance which each jurisdiction.
Interquartile ranges for tangible and intangible intercompany transactions, considering financial, services transactions as well as intangible transactions among related parties.
Transfer Pricing Audits
Assistance in administrative procedures with the tax authorities, including controversies in economic and administrative aspects.
Transfer Pricing Policy Design
Design and implementation of transfer pricing policies, considering the value chain within the related parties transactions.
Identification and categorisation of the intercompany transactions.
Transfer pricing policies aligned with the arm’s length principle and according to the OECD Guidelines methodology.
Assistance in the implementation and complete documentation of transfer pricing policies, considering the client’s internal procedures.
Identification of Risks
Companies face an increasingly complex business environment. Advice on planning, execution, risk management, documentation and dispute resolution is essential to achieve their commercial objectives.
Tax Authorities are aware of specific risk areas, such as:
- Restructuring operations.
- Business model.
- Transmission of intangibles among related parties.
- Intragroup services.
- Recurrent operating loses.
- Economic substance in intercompany transactions.
- Reliable benchmarking studies (quantitative and qualitative screening.)
- Intragroup financial transactions (interest rates).
- Segmented financial information for intercompany transactions.
- Documentation of mark-ups applied.
- Allocation of benefits and costs in intercompany transactions.
APAs (Advance Pricing Agreements) and MAPs (Mutual Agreement Procedures)
Preparation or verification of a cooperation model between related entities in order to submit an application for an Advance Pricing Agreement.
Support in preparing an application for an Advance Pricing Agreement and in developing the transfer pricing documentation requirements.
Transfer pricing consulting in negotiations and in the process of obtaining an Advance Pricing Agreement.
Support in the preparation of the application for initiating the Mutual Agreement Procedure in the case of double taxation, as well as support and representation in international administrative proceedings.
Case studies
Case studies from our practice
Our case studies show how we have helped a variety of clients solve their business challenges. Each case study presents a unique approach and specific solutions tailored to their needs.
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Prípadová štúdia 3
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Prípadová štúdia 4
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Transfer pricing
Justice in pricing certainty in business
Our goal is to cover the entire territory of Slovakia. Find your partner too.
Dravecký & Partner Tax
Daňové poradenstvo
Bratislava
Emineo Partners
Daňové poradenstvo
Bratislava
ETL EAST
Daňové poradenstvo
Košice
Services
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