Transfer pricing
Transfer prices are the prices set for transactions between related parties, which should reflect the prices that would be agreed upon between independent entities under comparable conditions. Properly setting and documenting transfer prices helps companies avoid tax risks and potential penalties from tax authorities.
We can assist you with the following:
We support the preparation of TP documentation in both Masterfile format—which summarizes key information about the entire group—and Localfile format, which focuses on specific intercompany transactions of individual entities in each country.
At RSM, we’ll help you set up your transfer pricing correctly and check for any inconsistencies in your current setup. We also offer concise internal analyses that focus on functions and risks of each entity to identify potential issues and suggest improvements.
Benchmark studies are increasingly used to support internal negotiations or determine arm’s length compensation for intercompany services. These concise analyses compare the relevant transaction—such as accounting services within a group—with market data to establish appropriate pricing.
Is your company undergoing a tax audit? We offer expert consultations to guide you through the audit process and, if necessary, we’ll prepare a supporting analysis to assess whether any tax adjustment imposed is fair and in line with market conditions.
An APA is a formal agreement with the tax authority confirming the pricing of specific intercompany transactions for a period of three years. It involves an administrative fee of CZK 10,000 per transaction. We’re happy to guide you through the process and help with the application.
Intragroup financing—especially in the real estate sector—is common. We’ll prepare an economic study to determine the market-based range for interest rates, ensuring your loan arrangements are defensible and in line with the arm’s length principle.
Are You Ready for the Challenges of Modern Business?
In today’s globalized world, where corporate structures are increasingly interconnected, transfer pricing is becoming a critical element of transparent and successful business management. It’s not just about compliance—it’s about gaining a strategic advantage that can enhance your competitiveness and financial stability.
Imagine your company passing a tax audit seamlessly, while others face challenging questions and potential penalties. That’s the reality we can help you achieve. Properly set and thoroughly documented transfer pricing is both your shield against unexpected tax liabilities and a bridge to more effective communication with tax authorities.
Our transfer pricing services will help you navigate the complex landscape of the arm’s length principle. Whether you’re selling goods, providing services, or sharing intangible assets within your group, we ensure your transactions are priced fairly and transparently—just as if they were conducted between independent parties.
With an increasing focus by tax authorities on transfer pricing audits, the time to act is now. Our solutions free you to focus on what you do best—growing your business.
By setting your transfer pricing correctly, you’ll minimize risk, optimize your tax position, and gain a competitive edge. With us, you’ll stay one step ahead—ready to face global challenges with confidence and professionalism.
Contact us today and discover how we can turn transfer pricing from a potential threat into a strategic strength for your business.
