1. Elaboration of Technical Studies of Transfer Pricing or Specific Documentation of the Taxpayer (Local File)
We elaborate the Technical Study of Transfer Pricing or Local File that contains the pertinent information to analyze the transfer prices in the operations between a company and its related or related parties, for tax purposes, and/or transactions carried out with countries or territories with low or zero taxation, taking into consideration the formalities required by the tax rules and the practice or casuistry of each country. This information includes the financial data of such specific operations, a comparability analysis, and the selection and application of the transfer pricing method, according to the regulations of each country, in order to demonstrate whether the transactions analyzed comply with the principle of arm’s Length.
2. Elaboration of Master file or specific documentation of the group.
We elaborate the Master File, that will collect standardized information corresponding to all the members of the multinational group. According to the Guidelines submitted by the Organisation for Economic Co-operation and Development (OECD), such documentation should include the organizational structure of the multinational group, a description of the Multinational Enterprise (MNE) business, the Multinational Enterprise (MNE) intangibles and the financial and fiscal positions of the Multinational Enterprise (MNE).
3. Elaboration of Country by Country Report.
We elaborate the documentation Country by Country Report, that allows a multinational company to verify the fulfillment of transfer pricing obligations at world-wide level, respecting the logic of contribution according to the generation of value that occurs in each Country. For this, it must present financial and accounting information of the multinational in all the countries where it has operations.
4. Definition of Transfer Pricing policy.
Technical analysis that seeks to establish a structure and optimal valuation of transactions between related or related parties and / or transactions with countries or territories with low or zero taxation, in order to verify that the transactions analyzed comply with the arm´s length principle, and that the company keeps the corresponding supporting documentation.
5. Advising on contentious transfer pricing processes.
Service that involves the diagnosis, defense strategy and elaboration of the transfer pricing contentious process (according to the formalities of each country) in order to provide adequate advice to our clients against tax inspections or requirements in the matter of transfer pricing. requerimientos de las Administraciones Tributarias en materia de precios de transferencia.
6. Advice on the negotiation of Advance Pricing Arrangements (APA’s).
The APA´S are agreements held between taxpayers and Tax Administrations, of one or more countries looking forward to establish, with anticipation, the compliance of the arm’s length principle in transactions between related parties, and / or transactions with countries or territories with low or zero taxation. So, the process to get to an agreement between the taxpayer and the Tax Administration includes certain technical aspects, the most important of which are: the transfer pricing method which has to be allowed by the norm of each country in order to be applied, comparison criteria and adjustments. Our service includes the elaboration and advising up until the APA is approved by both parts, the taxpayer and the Tax Administration.
7. Technical Studies of Market Value.
Elaboration of Technical Studies where the market value is determined for companies or intangible goods, such as trademarks or royalty rates..