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Transfer pricing documentation
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Competence as a basic value
Competence
Over 10 years AIM has cooperated with transnational corporations in various industries and markets.
Methodology
An arsenal of methods for pricing and analysis of wide range of products and services.
Over
30
packages of Transfer Pricing documentation in 2016
Responsibility
We guarantee timely preparation of the documents and defend a client’s interests during tax audits.
Reliability
We use trustworthy sources of information such as Ruslana, Spark, State statistics, and specialized periodicals - MetalBulletin, Platts, RoyaltyStat and others.
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Describing a tax payer’s activity
Identification of controlled operations; confirmation of their conformity to the law; detailed market description.
Describing a tax payer’s activity
1. Description of a controlled operation
2. Description of the market where a tax payer operates
Describing the group of companies
Description of the organisational structure of the group of companies; their activity; a list of the group’s competitive advantages.
Description of the Group
1. The Group’s property structure including persons who influence pricing
2. A list of persons which made a controlled operation
3. The Group’s main competitive advantages
Selecting a transfer pricing method
Selection of transfer pricing methods
1. Description of pricing on controlled operationsх
2. Selection of a transfer pricing method according to art.39 of Tax Code of Ukraine:
2.1. The CUP Method
2.2. The Resale Price Method
2.3. The Cost Plus Method
2.4. The Transactional Net Margin Method
2.5. The Transactional Profit Split Method
3. Information sources
4. Approach to economic analysis
5. Conclusion
Functional analysis
Functional analysis (separately for each kind of controlled operations and kind of contract)
1. General information
2. Description of main functions of Buyer and Supplier
3. Description of main risks of Buyer and Supplier
4. Conclusion on the results of functional analysis
Defining a market range of prices / profitability
Defining a market range of prices / profitability
1. Description of the approach to the application of the CUP method / net profit
2. Calculation of the market range of profitability according to the provisions of Tax Code of Ukraine
3. Making primary selection
4. Analysis of comparativeness of internal operations on key factors
5. Application of corrections to provide comparativeness of operations
6. Checking comparativeness criteria manually
7. Calculation of the market interval of prices / net profitability
8. Conclusion
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