TECHNICAL STUDY OF TRANFER PRICING – LOCAL FILE

The elaboration of the Technical Study of Transfer Pricing or Local File is based on the international standards and the legislation about Transfer Pricing applicable to each country. We are involved in the analysis and execution of all the phases of this report.

MASTER FILE

We give support for the fulfillment of the information needed for the Master File. This file contains standardized information relevant for all MNE group members, including its overall transfer pricing policies for the creation and ownership of intangibles and its financial activities.

COUNTRY BY COUNTRY REPORT

We give support for the presentation of the Country by Country Report which demands to provide fiscal information at the level of each jurisdiction regarding their global allocation of the income, economic activity and taxes paid among countries according to a common template.

BENEFIT TEST- INTRAGROUP SERVICES

Evaluation and revision of operations involving “intragroup services” in order to be prepared for the compliance of the Benefit Test to demonstrate that the services were in fact received. This is a requirement for the deductibility of intra-group service charges.

VALUATION OF COMPANIES, STOCKS AND INTANGIBLES

Consultancy to determinate the economic value of a company. Valuation is used by financial market participants to determine the price they are willing to pay or receive for the sale of a business.

STRATEGIC PLAN AND AUDIT SERVICES

Advice in the planning of operations with related parties and/or entities located in tax havens. Technical support against tax audits of the local tax administration.

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