Transfer Pricing

Transfer Pricing

A turbulent environment, local regulatory specifics and significant potential penalties

A turbulent environment, local regulatory specifics and significant potential penalties

Transfer pricing (TP) is increasingly becoming a hot topic for Macedonian tax residents. 

In an era of continuous globalization where intercompany transactions have become part of the day-to-day business of all multinationals, the Macedonian tax authorities start to pay more attention on this particular topic.

More and more companies recognize that effective transfer pricing policies may go far beyond simply enabling them to comply with local rules. Addressing TP issues before transactions actually occur may turn transfer pricing policies into strategic tools for supply chain decisions, as well as for global tax planning.

KPMG’s Transfer Pricing Services practice helps companies develop and implement economically justifiable transfer prices, document policies and outcomes and respond to challenges from the tax authorities. Transfer pricing is therefore a critical issue for all multinationals, and one that requires effective tax planning.

KPMG in Macedonia is here to help

We help companies document transfer prices in accordance with the specific local transfer pricing rules as well as the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. We respond to rapid tax authority challenges, implement economically justifiable transfer pricing policies and execute forward-looking tax planning. 

We can help companies manage their transfer pricing issues through such services as:


To assist in developing economically supportable transfer pricing policies and in executing forward-looking tax planning.


To provide insightful advice on developing and implementing policies, procedures, controls and systems for setting, monitoring, and testing intercompany transactions.


To help resolve transfer pricing disputes through various services, including assistance with advance pricing agreements, competent authority negotiations, arbitration, and litigation support.

Compliance and documentation

To help manage risk within the current environment of detailed transfer pricing regulations, strict documentation requirements, sophisticated audit practices, and significant penalties for non-compliance with an objective point-of-view.

Adapting to change

Forward-thinking companies recognize that effective global transfer pricing policies must do more than simply enable them to comply with national rules. They know transfer pricing issues have to be addressed long before transactions actually occur and they try to make their transfer pricing policies into strategic tools for investment and supply chain decisions, as well as for global tax planning.

Our advantages:

  • Proven track record
  • Dedicated TP team with international experience
  • Clients in a diverse portfolio of industries
  • Experience in various types of transactions
  • Access to specialized databases


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