Transfer pricing is one of the most important - and most demanding - areas of tax law, and it now affects a growing number of businesses that operate within capital groups or work with related parties. Incorrect settlements, missing transfer pricing documentation, or a flawed transaction analysis can lead to serious tax consequences and a higher risk of a tax authority audit. This e-book was written for companies that want to bring order to their transfer pricing processes and better understand their documentation and settlement obligations.
The publication explains, in plain terms, what transfer pricing is, when the documentation obligation arises, and how to prepare your company for a possible tax audit. It also covers transfer pricing adjustments, settlements with tax havens, and transactions between related parties. It's a practical resource for businesses that want to strengthen their tax security and manage the risk tied to settlements within the group.
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Table of contents
1. Related-party transactions – transfer pricing
2. Transfer pricing adjustments
3. Transactions with tax havens
4. Re-invoicing between related parties
5. Preparing for a transfer pricing audit
6. Transfer pricing documentation
Transfer pricing – what it is and who it affects
Transfer pricing applies to businesses that carry out transactions between parties related through capital, personal or organisational ties. In practice, transfer pricing obligations now cover a growing number of companies – both large capital groups and mid-sized businesses that settle accounts internally between group companies.
In the e-book, we explain what transfer pricing is, which transactions are subject to documentation obligations, and when a business should prepare transfer pricing documentation. We also cover the basic concepts around related parties and the rules for applying market prices in settlements between companies.
Transactions with related parties and intra-group settlements
Settlements between related parties call for careful preparation and properly documented terms of cooperation. This covers matters such as the sale of goods, the provision of services, loans, licences, and the re-invoicing of costs between companies within the same group.
The e-book covers the key rules on controlled transactions and the tax obligations tied to settlements within a capital group. We also explain what should be factored in when preparing a transfer pricing policy, and how to bring order to the process of documenting transactions.
Transfer pricing documentation – what obligations does a company have
One of the most important obligations for businesses operating with related parties is preparing correct transfer pricing documentation. Missing or incorrect documentation can increase tax risk and lead to disputes with the tax authorities.
In the e-book, we go into detail on when the obligation to prepare transfer pricing documentation arises, and what information needs to be included in the local and group documentation. We also cover the comparability analysis, reporting obligations, and preparing the data required by the tax administration.
Transfer pricing adjustments and tax security for your business
Transfer pricing adjustments are one of the key issues affecting the accuracy of tax settlements between related parties. In practice, businesses often have questions about how to make these adjustments and what conditions must be met for them to comply with the regulations.
In the e-book, we cover the rules for making transfer pricing adjustments and their impact on a company's tax settlements. We also explain what steps are worth putting in place to limit tax risk and keep your settlements compliant with the applicable regulations.
Transactions with tax havens and additional documentation obligations
Transactions with entities based in countries treated as tax havens are a particular focus for the tax authorities. In these cases, businesses may face additional documentation obligations and closer scrutiny from the tax administration.
The e-book explains what obligations arise when working with tax-haven entities, and what procedures are worth putting in place to limit tax risk. We also cover transaction analysis and documenting international cooperation.
How to prepare your company for a transfer pricing audit
Transfer pricing audits are among the most demanding tax proceedings, which is why properly preparing your company matters enormously for its overall tax security. The tax authorities are increasingly scrutinising settlements between related parties and how transaction terms are set.
In the e-book, we walk through what a transfer pricing audit looks like and which documents and procedures are worth preparing in advance to streamline the whole process. We also explain which areas the tax authorities look at most closely, and how to bring order to your internal documentation and settlement processes.
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Who is this e-book for
This e-book was written for businesses operating within capital groups, company owners, management board members, and anyone responsible for finance and tax settlements at companies that carry out transactions with related parties. It will be especially useful for businesses that want to bring order to their documentation, strengthen their tax security, and prepare more effectively for a potential audit.
The publication will also work well for accounting departments, financial specialists, and tax compliance professionals who need a practical resource on transfer pricing, tax documentation, and settlements within a capital group.
