1. Preparation of the Local Report – Transfer Pricing Technical Study or Taxpayer Specific Documentation
We prepare the Local Report or Transfer Pricing Technical Study that contains the relevant information to analyze the operations between a company and its related parties, for tax purposes, and/or transactions carried out with countries or territories of low or no taxation (or non-cooperating countries or territories), taking into consideration the formalities required by the tax regulations and the practice or casuistry of each country. Such information includes the financial data of the operations, a comparability analysis, and the selection and application of the transfer pricing method, according to the regulation of each country, in order to prove whether the transactions analyzed comply with the Arm’s Length principle.
2. Preparation of the Master Report or group-specific documentation.
We prepare the Transfer Pricing Master Report, which must include standardized information corresponding to all the companies or entities that comprises the business group. In accordance with the Transfer Pricing Guidelines developed by the OECD (Organization for Economic Cooperation and Development), this Report must include the organizational structure of the business group, a description of the business or businesses, intangibles, and financial and tax positions, among others.
3. Preparation of the Country-by-Country Transfer Pricing Report.
We prepare the Transfer Pricing documentation Country by Country Report, which allows a multinational company to verify compliance with its Transfer Pricing obligations worldwide, taking into consideration the generation of value produced in each State. For this purpose, financial and accounting information of the corporate group must be submitted in all the countries where it has operations.
4. Profit Test.
The service of preparation of the Profit Test Study is provided for the review and evaluation of service operations between related parties. In this way, the taxpayer must document and provide information that demonstrates the effective rendering of the service, its nature and actual need, the costs and expenses associated with the service, as well as the reasonable criteria for the allocation of such costs and indirect expenses. In addition, it should be noted that companies must have the appropriate documentary support that justifies the existence of the service, to comply with the conditions required by the Tax Administration and qualify for the deduction of costs and expenses.
5. Technical Market Value Study.
Our Technical Market Value Studies take as reference the accounting, financial and legal information provided by the companies, the technical knowledge applied using updated valuation methodologies and tools, and what is established by the legislation of each country. In this way, a value and/or economic-financial indicator is determined according to the market conditions of full competition and the needs of management decision making. We offer valuation services for companies in different economic sectors, fixed and intangible assets, royalty rates, interest rates, among others.
6. Advice in contentious processes of Transfer Pricing.
Service that involves the diagnosis, defense strategy and development of defense strategy, according to the formalities of each country, to provide adequate advice to our clients in the event of audits or requirements of the Tax Administrations in transfer pricing matters.
7. Transfer Pricing Planning.
Technical analysis that seeks to establish an optimal structure and valuation of operations between related or related parties and/or transactions carried out with countries or territories of low or no taxation, in order to verify that the transactions analyzed comply with the Arm’s Length principle, and that the company maintains the corresponding supporting documentation, taking into consideration the particularities of the legislation of the country where the company or business group will operate.
8. Advice on the negotiation of Advance Pricing Agreements with the Transfer Pricing Administration (APA).
The APAs are agreements entered into between taxpayers and Tax Administrations of one or more countries, which seek to establish, in advance, the technical criteria to carry out a valuation for Transfer Pricing purposes with respect to transactions between related or related parties, and/or transactions carried out with countries or territories of low or no taxation. Thus, a process is initiated in which an agreement must be reached on certain technical aspects, the most important of which are the following: the method allowed by each country’s standard to be applied, comparison criteria and adjustments. Our service includes the elaboration and accompaniment until the effective conclusion of the APA with the Tax Administration.
9. Technical Report for Commodities Analysis and submission of the corresponding Statement.
The service includes the preparation of a risk report in case the so-called Sixth Transfer Pricing Method (Comparable Uncontrolled Price in its external version) is applied, in the export and import transactions of commodities as well as the preparation of an economic, financial and technical report, which aims to verify that the transactions carried out by the company are subject or not to the so-called Sixth Transfer Pricing Method, if applicable.