Transfer Pricing

TPA Horwath Advisors have extensive experience in all types of Transfer Pricing projects, including the following:

  • Transfer Pricing Analyses (comprehensive projects designed to estimate the arm’s length prices of goods, services or intangible assets)
  • Benchmarking Study Projects (simplified analytical projects which aim at mitigating the risk of applying the so-called Comparable Uncontrolled Price method in the event of dispute with tax authorities)
  • Quick Review Projects (review of Client’s settlement systems, analysis of functions, contractual arrangements with related parties and their actual implementation for transfer pricing risks, and identifying risk mitigation methods)
  • Preparation of documentation in accordance with Article 9a Corporate Income Tax Act (CIT Act)
  • Preparation or support in the development and implementation of pricing policies of holding companies, taking into account the risk mitigation of transfer pricing
  • Assisting or representing Clients in tax proceedings and administrative litigations in matters relating to transfer pricing
  • Transfer Pricing Training, including advising client personnel on how to develop and update documentation which is consistent with Article 9a of the CIT Act
  • Preparation of tax opinions and expertises in respect of transfer pricing.