Transfer Pricing is a model of pricing for goods or services between affiliated or interdependent entities. This model operates on internal rules agreed upon between the entities rather than strictly following market forces.
Russian legislation classifies transfer pricing transactions as controlled transactions for which taxpayers must file notifications with the tax authorities. Not doing so may lead to significant tax risks.
Transfer pricing regulations are relatively new and can be cumbersome for business to handle on their own. Alinga offers a unique modular approach to transfer pricing projects which allows us to help our clients to stay compliant with the Russian legislation at a relatively low cost.
Let Alinga's extensive experience in tax and business consulting, business analysis, and legal support work for your business. We can design compliant transfer pricing systems, improve existing systems, and help you maintain practices to make sure that your business stays compliant and competitive.
Modular Transfer Pricing (TP) Services:
Transfer Pricing Consulting:
- consulting on general TP issues
- structuring intra-group transactions,
- adopting policies of foreign companies to the requirements of Russian legislation
- preparing objection responses to post-audit tax claims.
Diagnostics of TP-Associated Risks:
- transaction inventories
- industry analysis
- analysis of existing TP procedures
- verification of economic analysis performed by the company
- deliverable: a report on the condition of the existing TP system reflecting principal risks and consequences for the company.
Inventory of Transactions, Preparation of TP Documents:
- description of controlled transaction
- description of the group of companies
- functional analysis
- selection of pricing method for tax purposes
- description of information and data sources
- calculation of the market price interval (profitability margin).
- deliverable: documentation packet including a report of procedures conducted and necessary addendum documents.
Preparation and Filing of TP Notifications
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