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Transfer prices

Transfer prices are in the focus of interest of the tax authorities as an inevitable consequence of global economic development and the emergence of large multinational companies that operate in many countries through their subsidiaries and affiliates.

Why has this caught the attention of the tax authorities? On the one hand, the aspiration of the tax authorities is to collect as much tax revenue as possible and thus enable the functioning of the state apparatus, and on the other hand multinational companies through controlled transactions with affiliates have and use the ability to transfer profits from higher tax systems to higher tax systems with a lower income tax rate and as a result pay lower income tax. This fact imposes increasingly complex requirements, both on the part of tax administrations that must create a mechanism for checking the compliance of controlled transactions with the principle of "out of reach" and market principles, and on the taxpayers themselves who have the obligation to prepare transfer pricing reports. transaction with the principle of "out of reach" through the most reliable assessment in accordance with available data.

The topic of transfer pricing is equally important from the point of view of the tax administration, both for international business and for transactions performed between related parties in the country.

To make it easier for our clients to meet the above obligations and requirements regarding transfer pricing issues, our company provides the following professional services:

  • Preparation of Transfer Price Reports,
  • Advising on the preparation of the Transfer Pricing Report,
  • Development of transaction comparability analysis, functional analysis of controlled transactions and other analyzes,
  • Analysis and continuous consultation on pricing policy with related parties,
  • Advice and assistance in drafting intercompany contracts,
  • Support in the tax control process.

Legal framework of our services - Legal and professional regulations that represent the framework of our engagement and work in providing services related to transfer pricing are:

  • Law on Corporate Income Tax of the Republic of Serbia
  • Ordinance on transfer pricing and out-of-hand methods applied in determining the price of transactions between related parties and
  • OECD (Organization for Economic Co-operation and Development) guidelines for the application of transfer pricing rules for multinational companies and tax administrations, translated and published by the Serbian Fiscal Society in July 2010

Auditors, advisors, strategists, problem solvers, focused on excellent service and empowering clients to continuously develop their business.