Introduction

In an enormously globalized and increasingly interconnected economy, where a large part of international trade is carried out by multinational groups that operate in different geographies through their related companies, the planning and execution of transfer pricing aspects takes on vital importance.

Taking this in consideration, the prices at which a company transfers goods or services to its related parties abroad and/or located in free trade zones, or to persons, entities or companies located, residents or domiciled in tax havens; must be in compliance with the arm’s length principle, which establishes these transactions must be agreed taking into account the conditions that would have been used in comparable operations with or between independent parties.

The current business context challenges multinational companies to take control and manage the compliance and risks associated with the transfer pricing regime in accordance with applicable local and international regulations, in particular with the OECD Guidelines.

At FTC, we are committed to our clients, providing them solutions according to their development needs and advising them through the following consulting and tax compliance services:

Consulting services:

  • Determination of the arm’s length remuneration to be agreed in intercompany transactions concluded with related parties abroad or located in a free zone;
  • Structuring and reviewing of transfer pricing policies of Multinational Enterprises;
  • Preparation and negotiation of Advance Pricing Agreement (APA´s) with Tax Authorities;
  • Determination and planning of the Group’s value chain;
  • Financial valuation of tangible and intangible assets; and
  • Documentation and elaboration of defense files.
Compliance services

  • Elaboration of transfer pricing formal duties:
  • Informative return;
  • Local file;
  • Master file;
  • Country by Country report (CbCr); and
  • CbCr notification.

 

  • Assistance and support in the submission of the taxpayer’s formal duties;
  • Reviewing of the transfer pricing supporting documentation (local and master files) prepared by the company or its Head Office; and
  • Translation of supporting Documentation (local and master files) prepared by the company or its Head Office.
Resolution of disputes with tax authorities

  • Analysis of the defense files prepared by the Company;
  • Elaboration of responses and support in the different procedural stages of disputes with tax authorities;
  • Preparation of technical expertise;
  • Identification and calculation of sanctions derived from non-compliance to the transfer pricing regime.