Transfer Pricing Documentation
The Institute prepares tax documentation of transfer prices by local file and master file as well as tax documentation for low value added transactions. The Institute also provides services related to the settlement of business restructuring transactions, in particular calculates the (estimated) compensation payment (exit payment).
Pursuant to the provisions of the Corporate Income Tax Act and the Act on Income Tax from Individuals, taxpayers conducting intra-group transactions after meeting statutory requirements are obliged to have transfer pricing tax documentation.
We divide the documentation into two types:
- Local file
- Master file.
The local file consists of 4 elements:
The master file consists of the following elements:
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