Transfer Pricing

Transactions within a group of multinational as well as local companies have a significant impact on the results and tax obligations of individual entities. The Czech tax authorities therefore consider transfer pricing their priority. According to our recent experience, transfer pricing inspections are the rule rather than the exception. If a company underestimates or under-documents transfer pricing, it usually results in a complicated and lengthy inspection by the tax authority. This may then lead to additional tax, penalties, late interest and also negative publicity. The significance of transfer pricing has been growing in parallel with the OECD’s BEPS action plan.

We are able to support you – not only in the case of a legal dispute, where it is necessary to address both substantive and procedural arguments in time. We can help you configure and implement group business models and transactions right at the beginning, so that the tax administrator does not have a reason to question them. We will process transfer pricing documentation for you or file a request in your name for their binding assessment with the tax authority. In the follow-up negotiations with the tax administrator, our experts with many years of experience will support you, both in local and cross-border disputes.

Using international and local paid databases, we will prepare comparative studies for you to establish the usual market values of profit level indicators, licencing fees, interest rates or bank guarantees. As certified valuation experts, we are authorised to issue transfer pricing documentation in the form of an expert opinion, which, in light of the current case law, represents strong evidence in disputes with tax authorities.