Services

1. Elaboration of Transfer Pricing Technical Studies.

We elaborate the Technical Study of Transfer Pricing or Local File that contains the pertinent information to analyze the transfer prices in the operations between a company and its related or related parties, for tax purposes, and/or transactions carried out with countries or territories with low or zero taxation, taking into consideration the formalities required by the tax rules and the practice or casuistry of each country. This information includes the financial data of such specific operations, a comparability analysis, and the selection and application of the transfer pricing method, according to the regulations of each country, in order to demonstrate whether the transactions analyzed comply with the principle of arm's Length.

2. Planning Advisory Transfer Pricing

Service that involves the diagnosis, defense strategy and elaboration of the transfer pricing contentious process (according to the formalities of each country) in order to provide adequate advice to our clients against tax inspections or requirements in the matter of transfer pricing

3. Advice on contentious Transfer Pricing processes.

The APA's are agreements held between taxpayers and Tax Administrations, of one or more countries looking forward to establish, with anticipation, the compliance of the arm’s length principle in transactions between related parties, and / or transactions with countries or territories with low or zero taxation. So, the process to get to an agreement between the taxpayer and the Tax Administration includes certain technical aspects, the most important of which are: the transfer princing method which has to be allowed by the norm of each country in order to be applied, comparison criteria and adjustments. Our service includes the elaboration and advising up until the APA is approved by both parts, the taxpayer and the Tax Administration

4.- Filling and / or advice in the Transfer Pricing informative affidavit. (Different forms assigned by the Directorate General of Internal Revenue)

Advisory service in the filling of the Transfer Price Information Statement.

 

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