Companies as part of their economic activity carried out a series of transactions with related parties, among which are the provision of services, financing, buying and selling assets, among others. In this regard, we note that the tax authorities have increased their interest in reviewing the issues of transfer pricing tax audits, validate whether transfer prices have been defined based on the principle of free competition and whether these have supporting documentation on how prices have been determined.
Market research consistently proves that, for international business, transfer pricing in intra-group transactions remains the most significant and contentious international tax issue. We design and assist in the planning of transfer pricing policy, advise on restructuring and internationalization processes.
Our services include:
International Transfer Pricing advice and planning
Restructuring – Transfer Pricing
We validate and value Mergers and Acquisition and Corporate transactions for Transfer Pricing purposes.
Related transactions, taxation, auditing and global documentation
Taxation of risks in Transfer Pricing and global documentation of related-party transactions.
Tax inspections and verification of related transactions
Assistance to taxpayers in tax inspection procedures and verification of related operations.
Preliminary agreements of valuation and double taxation avoidance
Negotiation of APA's with tax administrations and assistance in friendly procedures and international arbitration.