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Services breadcrumb-icon Tax advisory breadcrumb-icon Transfer pricing advisory

Transfer pricing advisory

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Transfer pricing is perceived by the tax authorities as a tax planning tool, which makes it a high-risk area that may potentially lead to a tax evasion. Transfer pricing is therefore now part of almost every tax audit.

Incorrect transfer pricing may lead to additional tax assessments, penalties, interest on late payments and, last but not least, negative publicity. Transfer pricing should, therefore, not be underestimated by any means.

Rödl & Partner's team of transfer pricing experts can provide you with a comprehensive service with an international reach and a very flexible and personal approach.

The following are examples of the typical services we provide in the transfer pricing area:

  • processing or revision of transfer pricing documentation (local file, master file)
  • setting up transfer pricing methodology or revising the existing transfer pricing system
  • preparation of a defence file to defend the costs of intra-group services (management, consultancy, etc.)
  • analysis of intra-group financing (verification or determination of the market rate of interest)
  • representation before the tax authority in the event of a tax audit, representation in appeal or court proceedings 
  • advising on profit allocation of permanent establishments
  • advising on structural group changes
  • assistance with country-by-country reporting
  • preparation of expert reports on transfer pricing

Transfer pricing documentation and an assessment of compliance with the arm's length principle may be prepared in the form of an expert opinion only for selected transactions. Similarly, an analysis may be prepared in the form of an expert opinion on the basis of which the related party transaction is yet to be set up. An expert opinion provides a higher degree of assurance and may come into play either during the tax audit or at any earlier stage.

In recent years, the Czech tax administration has been very actively focusing on tax audits of transfer pricing, focusing mostly on the arm's length profit margin of routine companies or the tax deductibility of costs for intra-group services. In all such situations, we can provide highly effective support in collaboration with our tax litigation team.

Contact

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Ing. Petr Tomeš

Tax Advisor (Czechia)

Associate Partner

+420 236 163 224

Send inquiry

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Ing. Martin Koldinský

Associate Partner

+420 236 163 227

Send inquiry
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