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TRANSFER PRICING

We bring comprehensive solutions in transfer pricing matter related to the formal obligations compliance; consulting; planning; advice and support in litigation processes and transfer pricing audits; advice for the request and negotiation of advance pricing agreement (APA); among others.

SERVICES

Compliance

    Preparation and review of:
  • Local file
  • Master File
  • Country by country report and notification
  • Informative return

Consulting

  • Preventive transfer pricing diagnostic
  • Preliminary analysis before the closing date of the financial statements and corporate income tax return
  • Transfer pricing analysis previously to the intercompany transaction is done
  • Advice in defense files
  • Punctual and daily consulting

Planning

  • Structuring of intercompany transactions in order to obtain efficiencies and minimize contingencies
  • Advice in transfer pricing policies and handbooks
  • Accompaniment in enterprise reorganization process under transfer pricing rules

Litigation

  • Counselling in litigation process
  • Advice in transfer pricing audits
  • Technical assessment services

Advance Pricing Agreements (APAs)

  • Advice and accompaniment for the request and negotiation of advance pricing agreement (APA) before tax authorities

Attribution of profits study

  • Preparation of the profits attribution to branches and permanent establishments study

Others

  • Special attorney services for the submission of the transfer pricing formal obligations

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