Preparation of transfer pricing report

The members of our team offer you a service for preparing transfer pricing reports in accordance with the requirements of the Law on Corporate Income Tax.

Transfer pricing refers to the prices established in relation to transactions of assets or the creation of obligations among related parties.

The status of a related party includes:

• Legal or natural persons that directly or indirectly participate in the management, control, or capital of the taxpayer, and
• Legal entities in which, as well as in the case of the taxpayer, the same natural or legal persons directly or indirectly participate in the management, control, or capital.

A legal or natural person participates directly or indirectly in the management, control, or capital of the taxpayer if that person:

• Owns directly or indirectly at least 25% of the taxpayer’s shares or ownership interests, or
• Has the actual ability to control the business decisions of the taxpayer.

A legal or natural person has the actual ability to control the business decisions of the taxpayer when:

• It owns or controls directly or indirectly at least 25% of the voting rights in the taxpayer’s governing bodies;
• It has the right to participate in at least 25% of the taxpayer’s profits;
• It is a family member of the taxpayer or is related to a family member.

A large taxpayer, classified in accordance with the regulation governing the criteria for determining large taxpayers, who engages in transactions with related parties, is obliged to submit transfer pricing documentation when submitting the Tax Return. This documentation is used to determine whether the terms of transactions with related parties comply with the arm’s length principle.

Transfer pricing of the transaction is determined by verifying compliance with prices established according to the arm’s length principle, which is determined by applying: