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The way we work
Modular architecture of transfer pricing
Project Map

Purpose

Developing Modular architecture of transfer pricing (hereinafter – TP Modules), its implementation for the Client, further support and its defense against tax authorities claims.

Subject

Client’s controlled transactions (historical and future).

Goals
  • Controlled transactions identification;
  • Pricing method selection for controlled transactions;
  • TP Modules development;
  • TP Modules operating support;
  • Defense of developed concept against tax authorities claims.
Mobile Unit
  1. TP Modules implementation
    • Assessment of:
      • the Client’s business processes for controlled transactions identification
      • possibility for use of defense measures stipulated by the law
      • adopted methods and compliance of applied prices with requirements of the law
    • Analysis of characteristics which may significantly influence transaction terms, pricing method selection for each transaction type
    • TP Modules system development:
      • Transaction Modules;
      • Calculation Modules;
      • Regulation Modules;
      • TP reporting Modules
  2. TP Modules support
    • TP Modules operating update considering new business circumstances
    • Expert support of TP Modules generation during reporting period
    • TP Modules final assessment before introduction to tax authorities
  3. Defense against tax authorities claims
    • Work on tax authorities’ requests within TP Modules
    • Representation of Client’s interests in tax authorities