TPA 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 the Corporate Income Tax Act (CIT Act)
- Preparation or support in the development and implementation of pricing policies of holding companies taking into account 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’s personnel on how to develop and update documentation which is consistent with the CIT Act
- Preparation of tax opinions and expertises in respect of transfer pricing.
