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