Transfer Pricing

Main services of Transfer Pricing

• TECHNICAL TRANSFER PRICING STUDY - LOCAL REPORT
  We provide advice to taxpayers for the preparation of the Technical Study of Transfer Pricing (ETPT) or Local Report (LF) based on international standards and the legislation on Transfer Pricing applicable to each country, taking care of the analysis and execution of all phases that comprise the realization of the Local Report.
• STRATEGIC PLANNING
  We provide technical advice regarding the planning of operations with related parties and / or tax havens. The result of this analysis includes the design of transfer prices that best adapt under decentralized structures seeking the effectiveness of the organization, optimizing the valuation of these operations, complying with the principle of full competition and avoiding contingencies with the Tax Administration.
• MASTER FILE
  The Master File (MF) collects standardized information at the business group level, including the nature of its global operations, its transfer pricing policies and the distribution of its benefits and economic activities worldwide, in order to allow administrations Taxes that assess whether there is a significant risk of transfer pricing.
• COUNTRY BY COUNTRY REPORT
  The Country-by-Country Report (CbCR) requires adding tax information at the level of each jurisdiction regarding to the worldwide distribution of benefits and taxes paid, as well as certain indicators of the location of economic activities in the tax jurisdictions in which the multinational group operates. The CbCR requires mentioning all the member entities of the group, as well as the nature of the main economic activities carried out by each of them.
• INTRAGROUP SERVICES – BENEFIT TEST
  According to the OECD Guidelines, to talk about an intragroup service it is necessary that there is an economic or commercial interest for the entity that receives this service and that the fact of receiving such benefit means a benefit in its commercial position. In that sense, it is important to indicate that the transfer pricing regulations of several countries in the region have incorporated the “Profit Test”, in which companies are required to provide the documentation and information requested by the Tax Administration, as conditions necessary for the deduction of the cost or expense resulting from the provision of intragroup services.
• VALUATION OF COMPANIES, ACTIONS AND INTANGIBLES
  Determination of the valuation of assets (shares, companies, intangibles) and liabilities.