- Transfer pricing controversy
- Transfer pricing due diligence
- Transfer pricing documentation
- Transfer pricing planning and implementation
- Advance Pricing Agreements (“APAs”/ Mutual Agreement Procedures (“MAPs”) assistance
- In-house training for transfer pricing teams
Transfer pricing controversy
- Management of transfer pricing inspections
- Transfer pricing dispute resolution
Transfer pricing due diligence
- Risks assessment focus on intercompany transactions/transfer pricing models
- Identification of gaps between the transfer pricing policy and the actual implementation of the transfer pricing policy/model.
Transfer pricing documentation
- Preparation of CbCR
- Assistance on the CbCR notification to the Slovak Tax Administration
- Preparation of Master File
- Preparation of Local File
- Preparation of benchmarking studies (visualization tool – transfer pricing analytics)
- Globally coordinated transfer pricing documentation - PwC’s Global Coordinated Documentation™ (GCD)
Transfer pricing planning and implementation
- Design/redesign of intercompany transactions in order to align them with the arm´s length principle
- Alignment of TP polices within the Group
- Preparation of internal TP Guidelines/Directive
- Alignment of IT tools with TP reports
Advance Pricing Agreements (“APAs”/ Mutual Agreement Procedures (“MAPs”) assistance
- Preparation of the petition
- Assistance during the APA/MAP process
In-house training for transfer pricing teams
- Transfer pricing basics
- Transfer pricing advance
- Customized trainings based on the company´s requirements
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