Transfer Pricing Risk Management

Transfer Pricing Risk Management

How to understand whether your company is exposed to transfer pricing risks? We offer to start with answering a few questions:

  • Step 1. Does the company carry out international business operations or transactions associated with business operations (as defined in Article 3 of the Transfer Pricing Law)?
  • Step 2. Are these operations significant for the company? Can these operations draw attention of the tax authorities?
  • Step 3. Is there a court practice of transfer pricing to be applied to such operations? Whose side do the courts usually take in such situations?
  • Step 4. Has the diagnostics of transfer pricing risks been performed? How substantial are the amount of potential risks? Are there any ways to mitigate the risks?
  • Step 5. Given the answers to previous questions, is the company ready to respond to the tax authorities’ inquiry regarding the transfer price matters?
  • Step 6. If my company is a member of the international group that has a turnover above EUR 750 million, has my company already submitted the country-by-country report? In what country? Is there an information exchange agreement between Kazakhstan and that country?
  • Step 7. Does the company have the qualified in-house specialists who can perform a high-quality diagnostics of risks and prepare the good documents to protect its TP?

Once you have answered the above questions, you may fearlessly go forward!

Do you need help?

Please, call our Transfer Pricing Hotline: we know answers to all these questions and much beyond
+7 771 781 8828

Connect with us