Transfer Pricing

Experience in providing Transfer Pricing Advice

The KONDOR Global through KONDOR-TP has extensive experience in providing transfer pricing services. In the last decades, transfer pricing has been and is likely to remain the focus area for company groups where relying on external expertise is not only cost efficient but is also a prerequisite to reach their tax risk mitigation goals.

Close cooperation of the transfer pricing professionals as members of KONDOR Global means that our Partners and Clients can rely on our service in all of their cross-border transactions, receiving assistance at the same quality.

The KONDOR Global can assist multinationals both in structuring and in documenting their intra-group transaction in a manner that limits their transfer pricing related risks to a manageable and desired level.

The KONDOR Global has thorough experience in providing benchmark studies for different types of transactions and activities, from manufacturing to IT service provision, from intra-group loans to guarantees, or from royalty transactions to licence fee payments.

Types of services

The KONDOR Global offers full range of transfer pricing services:
The preparation of Local Files with detailed functional, asset and risk analysis.
The preparation of divisional/global Master File documentation.
The preparation of benchmarking studies covering all types of inter- company transactions.
Review and advice on intra-group agreements, internal transfer pricing policies, internally prepared local files or master files.
Assistance in preparing and filing APA requests.
Valuation services related to intra-group transactions.
Litigation support and representation in front of the competent authorities.

Business Restructuring

Business restructurings by multinational companies have attracted increased scrutiny of tax authorities in recent years. Besides relocation of functions, business restructuring also includes conversion of businesses, for example the conversion of fully-fledged distributors into limited-risk distributors or the conversion of fully-fledged manufacturers into contract-manufacturers.

These new developments will require companies to involve more analysis and documentation when deciding to restructure. The KONDOR Global can assist to identify taxable events and perform studies to support the business restructuring in order to avoid or limit tax risks.

Valuation and business planning

The KONDOR Global assists clients with valuation and business planning services for tax and financial reporting purposes.

Experience

Dispute Resolution and Litigation Support

Transfer pricing is one of the major tax risks to be handled by corporations today. With the global corporate tax race putting pressure on state budgets, the tax authorities are forced to assign more and more resources both in terms of quality and quantity into auditing related party transactions in order to ensure such transactions are conducted at an arm’s length price and thus do not harm the tax base. Given that the determination of transfer prices is not an exact science, a more challenging stance by tax authorities might sometimes produce insurmountable difficulties for corporations globally.

KONDOR Global has wide experience in assisting clients when disputes arise:
Audit defense – assistance during the tax audit providing professional answers to questions raised by the auditors.
Appeals – assistance and filing of appeals.
Litigation – assistance as expert witnesses before the courts.
As a dispute prevention option, we have experience with APA or Advance Pricing Arrangements – an arrangement with the competent authority providing certainty on your transfer pricing methodology for future transactions.