In the modern tax legislative frameworks, management of intragroup transactions pricing (Transfer Pricing) is the key on conforming optimized tax policies in Multinational Enterprises (MNE’s). It is mainly related to the distribution of resources among the connected parties, taking also into account their complex organizational environment.
MNE’s shape their costing policies, considering the respective tax legislative framework and limiting the risk of over-taxation. This is due to misallocation of resources and double taxation.
The implementation of a mutual costing approach related to Transfer Pricing is a strategic objective of a wisely shaped development policy which leads to the fortification of a competitive advantage.
According to globally established auditing standards, it is possible for audit authorities to identify tax differences in transactions between related parties of an MNE Group, which may lead to double taxation, under the responsibility of the MNE which did not develop appropriate anticipating policies.
The above-mentioned risks, make necessary the development of a formed policy of Transfer Pricing that can lead to the following beneficial effects for an MNE Group:
- Reduce the possibility of tax differences by the audit authority
- Reduce the possibility of double taxation of Intragroup transactions between different national operational entities within a group
- Profitability increase, through proper management of the tax base
- Creation & monitoring of an international database of information which may be used as supporting data in tax audits, given the fact of common guidelines establishment for the Intragroup transactions documentation.
Mazars Transfer Pricing team has specialized Tax Consultants & Accountants Professionals who can help your business to ensure the fairness and accuracy of transfer pricing among related entities.
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Benchmarking
Our experienced transfer pricing team expertise in benchmarking studies in order to determine the market conditions in the transactions conducted by related and third parties as part of a crucial tax planning exercise providing the acceptable range of an arm’s length transaction.
Transfer Pricing Local Files
Ιn respect of transfer pricing compliance requirements oriented to test the arm's length nature of the related party transactions, we prepare local transfer pricing documentation files by implementing the relevant international regulations, and provide a customized transfer pricing strategy totally aligned to your business and operating profile.
cBc Report
Within the context of the transfer pricing compliance we are supporting the compliance arising from the implementation of BEPS actions including the annual reports and the disclosure of the specific information regarding the structure of the Groups, the allocation of the profits and the value chain.