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Transfer Pricing

The legal obligation of associated enterprises to keep books at internal transfer prices is applied particularly during profit distribution between domestic companies and their overseas subsidiaries, so that an international profit shifting between two associated enterprises through free internal invoicing is no longer possible.

For business relations of internationally affiliated companies, it must be possible to present bookkeeping records of cross-border internal transfer prices, failing which the companies face the threat of imposition of penalty estimates as well as special surcharges.

Within the framework of fulfilment of the obligation to keep books at internal transfer prices, we offer the following support:

• Preparation of internal transfer price documentation
• Implementation of internal transfer price systems
• Appraisal and check of existing internal transfer price systems
• Support in the event of internal transfer prices objected to by the Tax and Revenue Office