Transfer Pricing

A strong team of transfer pricing specialists including auditors, lawyers and professional appraisers, over many years of fruitful work has become a real business card of the EUCONLAW Groupp, which was one of the first law firms in Ukraine to establish Transfer Pricing Practices. The combination of knowledge and experience of the professional of different profiles allows to provide a synergetic approach to solving customer issues and properly respond to their requirements at all stages of service and cooperation.

EUCONLAW Group is a member of TPA Global, a global network of independent service providers, transfer pricing, tax assessment and customs professionals. Our membership strengthens the possibilities of narrow-profile consulting on transfer pricing within both the jurisdiction of Ukraine and the jurisdictions of other countries.

At the initiative of our company in 2013, the School of Transfer Pricing was established – a platform for training, exchange of experiences and discussions between experts in the field of Pricing Practices.

Our experts provide services as follows:

Preparation of a report on controlled transactions:

providing recommendations to optimize the structure of business operations;
Defining a list of transactions with unrelated counterparties whose prices/terms can be used as comparable;
conducting an audit (inventory) of business transactions in order to identify controlled transactions;

Preparation of transfer pricing documentation:

diagnostics of controlled operations;
search for comparable transactions/legal entities;
determining the price level in controlled transactions. Calculation of the price range/study of the market level of profitability;
preparation of a written report (full package of documents for submission to a supervisory authority).

Carrying out of the comparative analysis of activity of the party of the controlled operation with activity of comparable companies (benchmarking). Using Bureau van Dijk databases:

diagnostics of controlled operations;
search for comparable legal entities;
determining the price level in controlled transactions. Calculation of the price range and study of the market level of profitability.

Support during inspections in the field of transfer pricing:

prompt preparation of the necessary information on the subject of inspection;
representation of the company’s interests in the bodies of the State Fiscal Service of Ukraine.

Consultations in the field of transfer pricing:

on the application of tax legislation;
on report and documentation preparation;
on tax planning and building organizational structures.

Development and adaptation of internal regulations of the enterprise on control over observance of the legislation in the field of transfer pricing:

study of the specifics of economic activity of the company;
development of procedures for identification of controlled transactions;
identification of factors influencing the formation of prices and criteria for finding comparable transactions;
choice and substantiation of the method of determining the conformity of the price of the “outstretched hand” principle for each type of business transaction, preparation of an algorithm for its application;
identification of sources of information that can be used by the company, taking into account the specifics of its activities;
development of a procedure for preparing documentation to confirm the price of a controlled transaction;
distribution of functions and responsibilities between employees of the enterprise at each stage of control.

Legal support within the disputes on Transfer Pricing issues during administrative or judicial appeals against decisions of controlling bodies:

mediation at the level of administrative appeal;
full legal support during the consideration of transfer pricing cases in court.

Support of procedures of preliminary coordination with SFSU of pricing within the controlled operations:

comprehensive study of the specifics of economic activity of the enterprise;
preparation of an appeal to the SFSU and a complete package of documents for its consideration;
full support within the procedures for concluding an agreement with the SFSU.

Trainings for the company employees:

Within the training program of the School of Transfer Pricing and the International Forum “Transfer Pricing and International Taxation” we offer attend lectures, workshops, webinars and practical classes.