The transfer pricing analysis entails by the nature of the activity the examination of cross border transactions, thus the approach used by a network of professionals reuniting knowledge and local experience in each participating state to cross border transactions is the optimal solution. The participation of a network of professionals implies both creating a cooperating analysis framework and considering the local implications and regulations from each state participating in the transaction.
The status of member of the Altus Alliance international network of transfer prices allows us to collaborate with our partners in order to issue a documentation applicable to the entire group (master file) as well as adapting it for each subsidiary of the group. At the same time, we can approach projects regarding the international tax planning of the group or restructuring the group for tax optimizations, by considering the global and local implications.
The cooperation with our international partners in analyzing transfer pricing projects and international issues related to transfer prices, business restructurings and tax litigations offers us additional experience, a mature perspective, as well as the possibility to successfully approach any type of transaction starting with clients which activate in production/distribution and working up to transactions which require specialized knowledge (banking, energy, financial sector etc.).
Viboal FindEx’s experience in transfer pricing is characterized through an impressive number of finalized projects, the majority of them being examined by the Romanian tax authority and accepted without making corporation income tax adjustments. Our approach is concentrated on minimizing the adverse effects and on controlling the presentation process, by offering assistance related to the issued documentation. Thus, we make sure that the issued documentation will be correctly examined, completing, if necessary, our analysis.
Our services can be adapted according to the needs and budgets allocated by each client starting from simple solutions and moving up to more complex ones.
- Assistance during tax inspections for internally prepared documentation
- Assistance during administrative and judiciary procedures for contesting the results of evaluating the transfer pricing documentation by the tax authority,
- Drawing up the functional and economic analysis for significant transactions, i.e. providing comparability analyses,
- Revising master files and adding information in order to insure they are in accordance with the Romanian applicable law,
- Preparing the transfer pricing documentation, complemented by issuing a memorandum for the management and providing assistance during tax inspections,
- Preparing the transfer pricing documentation at a global level alongside the international practitioner team from Altus Alliance.
Viboal FindEx has access to the relevant databases for successfully approaching transfer pricing transactions, being capable to tackle every project, regardless of its complexity, assisted by an international team of professionals.
A part of the most recent projects are presented below:
- Preparing the transfer pricing documentation and arguing it during a tax inspection for a part of the most important Romanian companies which activate in the agriculture domain,
- Preparing the transfer pricing documentation for the most important bearing producer in Romania; the documentation was analyzed without setting any adjustments,
- Preparing the transfer pricing documentation for one of the most important R&D companies in Romania and successfully providing assistance during a tax inspection,
- Preparing the transfer pricing documentation for the mother company of an Italian group and providing assistance during a tax inspection of the Italian tax authority,
- Preparing the transfer pricing documentation for one of the most important multinational companies which produce concrete and aggregates; the documentation was analyzed without setting any adjustments,
- Completing a transfer pricing master file with a country file adapted to the Romanian regulations for one of the most important multinational companies which activate in the distribution of cooling equipment,
- Preparing the transfer pricing documentation for one of the biggest national groups which activates in the construction domain etc.