Transfer Pricing
Documentation & Strategy
We prepare comprehensive Transfer Pricing Documentation (TP Doc) in accordance with PMK 172/2023 regulations, and protect your company from arm's length pricing disputes.
Master & Local File
Preparation of master file and local file for affiliated transactions.
Benchmarking Study
Market benchmarking analysis using leading commercial databases.
Securing Your Affiliated Transactions
Tax authorities are increasingly scrutinizing the fairness of transactions between related parties (affiliates). Without strong TP Doc and proper benchmarking, companies risk large tax corrections that drastically affect business cash flow.
-
Master File & Local File
Structured according to OECD and DJP guidelines, outlining business profiles and transaction schemes.
-
CbCR (Country-by-Country Report)
Assistance with CbCR reporting for multinational groups according to global reporting obligations.
-
Fairness Assessment (Arm's Length Principle)
Determining the best transfer pricing method and finding reliable comparables.
