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Transfer pricing, transfer prices, prices applied between related entities, valuations for tax purposes

The RSM CZ Expert Institute offers qualified estimates of transfer pricing and proposals for/assessments of suitable transfer pricing applied between related entities within a holding group, in accordance with the requirements of the relevant tax regulations, and the processing of complete transfer pricing documentations.

What you can expect from us

In the area of transfer pricing, we will be happy to provide you with the following services, in cooperation with tax advisors:

  • Input analysis of the client’s transactions with related entities
  • Processing of proposals for new transfer pricing strategies within groups of related entities
  • Preparation and processing of complete transfer pricing documentations
  • Assessments or expert opinions regarding the transfer pricing setup, or the arm’s-length range
  • Assessments or expert opinions on the assessment of current transfer prices
  • The issue of applications for a binding assessment of transfer prices by tax authorities
  • Support in negotiations or representing the client in dealing with tax authorities.

In the domain of transfer pricing, we offer the processing of complete transfer pricing documentation, the assessment of the arm’s-length profitability ranges in the supplies of services and products, the setup of licence fees (royalties) or the determination of interest rates for intra-group financing. As an expert institute appointed by the Ministry of Justice of the Czech Republic, with our competences including the “reviewing of interactions between related entities from an economic point of view”, we are ready to assess your transfer pricing, including the issue of an expert opinion, which can serve as a strong argument in dealing with the tax administrator.

Reasons to choose RSM CZ

  • RSM CZ has a team of tax specialists and expert institute experts who deal with the issue of transfer pricing
  • We use a number of commercial databases for this purpose, especially TP Catalyst, RoyaltyStat and S&P Capital IQ
  • We have extensive experience with this issue and thanks to the fact that we are a member of RSM International, we are able to provide our services in an international context, in cooperation with our partners from other countries
  • The expertise aspect plays an absolutely key role in the setup of and/or support for transfer pricing. The specialists from our expert institute involved in the transfer pricing setup use their long experience gained in processing hundreds of valuations of various types of assets
  • We also offer the assessment of transfer prices in the form of an expert opinion.

Why we solve transfer pricing

Along with the growing importance of transactions between related members of multinational holding groups, there is also a growing need for the correct setting of transfer prices. The relations between related entities are under close watch by the tax administrations of individual countries, especially from the perspective of their impact on income tax assessment bases. Correctly set and documented transfer prices are something clients will appreciate during tax audits and, in general, any dealings with tax authorities.

Typical transactions between related entities include, for example, the sale of intermediate or final products, management services, marketing services, rights to use intangible assets (licences), the sale or rental of immovable or movable property, the provision of financial resources within a group of related entities, the provision of guarantees and other forms of securities, etc.

Tax regulations require that transfer pricing is determined in accordance with the arm’s-length principle, i.e. in amounts that are identical or similar to those which would otherwise be agreed between independent entities under normal business conditions. Violating this principle may lead to additional tax liability, including interest and penalties.

Contact persons

Martina Nekvindová

Consultant

+420 226 219 000

martina.nekvindova@rsm.cz

Rudolf Hájek

Senior Manager

+420 226 219 000

rudolf.hajek@rsm.cz

References

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