Transfer pricing
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Transfer pricing services
Transfer pricing services are one of the key activities of Nika Commerce.
Already at the stage of the initial consultation, we will be able to clearly say whether your business is among those who need thoughtful and competent advice on transfer pricing. We will help you develop a behavior strategy and tell you about further actions.
WHAT WE OFFER OUR CLIENTS
The list of services provided by Nika Commerce includes a whole range of transfer pricing services:
Preparation of notifications on controlled transactions;
Development of transfer pricing documentation for tax control purposes, including functional analysis, justification of the selected transfer pricing method, analysis of comparable transactions and calculation of market price intervals for transactions;
Consulting support on transfer pricing issues, identification and analysis of possible tax risks;
Preparation of statistical studies (benchmarking);
Representation of the client's interests in controlling organizations and in court.
COST OF SERVICES
The cost of preparing reports on controlled transactions depends on the number of contracts and the range of goods / services.
When ordering transfer pricing services from us, you can count on a quick solution of issues, identification of risks and professional advice from leading experts.
We will calculate all possible risks and assist in the preparation of notifications and documentation for controlled transactions. In addition, if necessary, we will help you in consulting your foreign counterparties, we will develop documentation to justify market prices.
CRITERIA FOR RELATING TRANSACTIONS TO CONTROLLED
Transactions come under control in the following cases:
Transactions between related parties, residents of Russia
if the amount of income exceeds 1 billion rubles;
one of the parties to the transaction refers to the payers of the MET, ESKhN, UTII and the transaction amount exceeds 100 million rubles;
one of the parties to the transaction is a resident of the Special Economic Zone and the transaction amount exceeds 60 million rubles;
one of the parties to the transaction applies the simplified tax system, is exempt from paying income tax (gambling business) or is a participant in the Skolkovo project and the amount of transactions exceeds 60 million rubles.
Transactions with foreign related parties
are considered controlled if the amount of transactions for a calendar year exceeds 60 million rubles.
Deals with third parties
all transactions with offshore companies, regardless of the amount;
transactions in the field of foreign trade in goods of the world exchange trade, regardless of the amount.
TIME OF PROVISION OF REPORTING ON TP
If there are controlled transactions, the organization must submit to the tax authorities:
May 20, 2021 - deadline for submitting the Notice of Controlled Transactions for 2020;
June 01, 2021 - the deadline for the start of inspections on transactions made in 2020. By this time, it is necessary to prepare the Transfer Pricing Documentation , with a justification of the price level. Within 30 days after the request, the organization is obliged to submit the documentation to the tax authority.
Organizations belonging to international groups of companies (MGK), whose total income (proceeds) according to the consolidated financial statements for the previous reporting period amounted to more than 50 billion rubles, must submit to the tax authority a Notification of participation in MGK by August 31, 2021 , as well as at the request of the tax authority - transfer pricing documentation, consisting of three levels:
"Country -by-country report" (CbCR);
"Global documentation" (Master File);
"National documentation" (Local File).
MINIMIZATION OF TRANSFER RISKS
Nika Commerce specialists have extensive knowledge in the field of transfer pricing, have significant experience in analyzing interdependent transactions and preparing transfer pricing documentation in accordance with the provisions of the current legislation of Russia.
To obtain comparable data, we use various information databases: RUSLANA, ORBIS, SPARK, AMADEUS, BLOOMBERG and others.
By contacting us, you will be able to reliably protect your business from claims from regulatory authorities in relation to controlled transactions.
Fill out the form and our specialist will contact you as soon as possible and prepare an individual offer
OUR PARTNERS
Our office
The address:
123112, Russia, Moscow, Presnenskaya nab., 12, Federation-East Tower, 18th floor
