In order to minimize the potential risks of transfer pricing, the taxpayer must proactively plan transactions with its related parties. Also, the taxpayer can define its transfer pricing policies in a way that will significantly reduce tax expenditures.

Significant tax risks also occur in situations where there are services that one group member company provides to another member, which are not invoiced (so-called transfer mispricing). For example, a parent company provides group accounting services, consulting services, legal services, or leases premises to a dependent entity, and provides those services free of charge. Such actions most often lead to VAT risk in terms of the right to withholding tax, the risk of recognition of expenses in the tax balance as well as from the point of view of gifts to related parties.

In order to define transfer pricing and reform current transfer pricing policies, our tax experts are at your disposal.