We provide consulting and preparation of the transfer pricing file.
The transfer pricing file is the document by which each taxpayer who carries out transactions with affiliated persons must justify the amount of the prices of those transactions and demonstrate compliance with the “market price”. Based on the information provided in the file, the tax inspector decides to accept or adjust the transfer prices charged by the taxpayer.
The file of transfer prices is mandatory to be prepared and submitted annually to the authorities by some large taxpayers. Small and medium taxpayers prepare this transfer pricing file only at the request of the tax inspection teams, when the transactions with affiliated entities exceed certain limits
The analysis of transfer prices implies by the nature of the activity the examination of cross-border transactions so that the approach of transactions by a network of professionals gathering local knowledge and experience in each of the states participating in cross-border transactions is the optimal solution. The participation of a network of professionals involves both the creation of a cooperative analysis framework and the consideration of local implications and regulations in each of the states participating in the transaction
BE THE FIRST TO KNOW YOUR RISKS IN THE RANGE OF MARKET VALUE
If we are talking about the profit tax, VAT or about the various forms of income tax of the affiliated persons (be they legal or natural, national or international), then we are certainly talking about the transfer prices and the Transfer Pricing Service of the National Agency Fiscal (“ANAF”).
An ancient teaching says that “man plans and God smiles.” If we were to adapt this aphorism to the realities of daily tax practices, especially transfer pricing, we can say that “the manager plans and ANAF smiles”.
It is no coincidence that we place this paraphrase here, but because we increasingly see disputes over transfer pricing between the ambitious management of affiliates and reluctant tax inspectors due to different approaches but also the lack of supporting documents for transactions with affiliates.
The analysis of transfer prices implies by the nature of the activity the examination of some cross-border transactions. The cooperation with our international partners in the analysis of transfer pricing projects and international cases regarding transfer pricing, business restructuring and tax litigation offers us an extra experience, a mature perspective, as well as the possibility to successfully approach any type of transactions starting from clients operating in widely represented industries (production / distribution) and reaching transactions that require specialized knowledge (insurance, banking, energy, etc.).
Teaha Management Consulting‘s experience in transfer pricing projects is characterized by an impressive number of completed projects, most of which target projects that have been examined by the Romanian tax authority and have been accepted without any profit tax adjustments. Our approach focuses on minimizing side effects and controlling the process of presenting the documentation regarding the transfer pricing file, by offering assistance for the prepared documentation. Thus, we ensure that the prepared documentation will be examined in a correct way, arguing and completing if necessary our analysis.