Transactions with related parties can pose significant tax risks. Many taxpayers only identify transfer pricing (TP) issues when preparing documentation and submitting the Transfer Pricing Report (TPR), at which point their ability to implement necessary corrections is limited. A financial audit presents an excellent opportunity to proactively identify risks related to intra-group transactions. As part…
The deadline for submitting the CbC-P notification for 2024 to the Head of the National Revenue Administration (KAS) is fast approaching—31 March 2025 (for entities whose financial year aligns with the calendar year). This obligation applies to entities that are part of corporate groups required to submit a Country-by-Country Report (CbC-R). What is CbC-P reporting?…
The new Notice of the Minister of Finance on the announcement of the type of base interest rate and margin for transfer pricing (safe harbor for financial transactions) has been published! Conditions for safe harbor in financial transactions The Finance Minister has updated the conditions authorizing the use of safe harbor simplification for financial transactions.…
Discover how to create a step-by-step transfer pricing policy designed to minimize and compliance and tax risks for your business. What is a transfer pricing policy? A transfer pricing policy outlines the rules for determining prices in transactions between related parties, ensuring they meet the arm’s length standard. This policy is essential for companies operating…
Cash pooling is a widely used solution among capital groups. It streamlines the management of funds across multiple entities and enhances liquidity control. This approach leads to cost savings and more efficient financial management within the group. Cash pool arrangement – what is it? Cash pooling is a liquidity management system designed for companies within…
As the year draws to a close, companies are preparing their final accounts for 2024. Now is the last opportunity to carefully review and make any necessary adjustments to settlements, pricing, or contract terms. The adjustments themselves continue to raise numerous interpretative questions, not only about their definition but also regarding the conditions for their…
Transfer pricing is essential for both businesses and tax authorities, as it involves setting prices for transactions between related parties, where there may be a risk of under-reporting income in one of the jurisdictions. For this reason, it’s important to ensure these prices are correctly determined, and then properly verified. In this post, we outline…
This is one of the key tools tax authorities use to verify transactions between related parties. With the TPR form deadline approaching, here’s a reminder of the essentials of transfer pricing reporting: What transfer pricing information is, What data it includes, Who is required to submit it, Who is liable for failure to submit, What…
The deadlines for meeting transfer pricing obligations for 2023 are fast approaching, especially for taxpayers whose fiscal year aligns with the calendar year: by October 31, local transfer pricing documentation must be prepared. by November 30, transfer pricing information must be submitted using form TPR-C. In this post, we address common questions surrounding the submission…
A comparative analysis, also referred to as a transfer pricing benchmark, is essential for: establishing transfer pricing in the arm’s length range, and fulfilling documentation requirements. How and why to perform a transfer pricing benchmarking? We conduct the analysis by comparing the prices charged (or the results achieved) in transactions between related parties with those…