• SERVICES

Transfer
pricing

Transfer pricing adjustments can be anticipated with a correct assessment of the Business Group’s business model and support for compliance with the principle of full competition in intercompany operations.

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Compliance with formal duties
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Transfer pricing consulting
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Support in litigation processes

For this, Jiménez Duarte Asociados has a team
of professionals that will allow you to:

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Under the application of the base erosion in the Tax Base and Profit Transfer (BEPS) of the G20 / OECD, we identify the main risk factors or contingencies in relation to intercompany operations, considering model of Business Group.

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Carry out a diagnosis of compliance with arm’s length principle in intercompany operations, anticipating end of year.

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Review of intercompany pricing policies and segmentation manuals.

Additionally, we support you in study of attribution of income and occasional earnings for Permanent Establishments and Branches of Foreign Companies. Although  attribution study should only be delivered to Tax Authority upon request by  same,  Permanent Establishments and Branches must have this analysis as a support for their tax accounting and therefore it can be required within the audit processes advanced by  tax auditors.

In this matter, Jiménez Duarte Asociados offers support for review of business model and  documentation of  functions, assets, personnel and risks assumed, evaluating compliance with  arm’s length principle of attributable operations, as well as  standards contained in  Tax Code on  realization of income, costs and deductions.

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