Consultancy services in the field of transfer comparison is to identify the agreed price in a transaction related entities in nutariste group (i.e., between an enterprise under common control).
From the standpoint of taxation, transactions between related parties should be carried out in accordance with the principle of “van lookups Taruk” ie. According to market conditions. Any difference between the transfer price and the price in line with the principle of “van dohvataruke” requires correction of taxable income for purposes of calculating the tax on corporate profit. Taxpayers are obliged at the request of tax authorities
submit supporting documentation to determine transfer prices that are applied in transactions between related parties.
The obligation of the taxpayer to keep the documentation of transfer prices is caused by the request of the legal regulations on disclosure transfernihcena. S obziromna that the taxpayer is required to provide proof of applicable transfer pricing documentation on transfer pricing serves to demonstrate that the transaction sapovezanim parties carried out in accordance with the principle of “arm’s length”.
Rules on transfer pricing methods and on the principle of “arm’s length” applied in determining the price of a transaction between related parties ( “Official Gazette of RS”, No.61 / 2013), the Law on Corporate Income Tax Law ( “Official Gazette of RS” , nos. 25/01, 80/02, 80/02 – dr. law, 43/03, 84/04, 18/10, 101/11, 119/12 and 47/13), as well as the guidelines of the OECD (Organization for economic cooperation and development) for the application of the rules on transfer pricing for multinational enterprises and tax administrations, which have been translated and published by the Serbian fiscal Association July 2010 regulates issues related to the Study on transfer pricing and reporting on this basis.
The goal of our company is that by applying the Law on Corporate Income Tax Law, the Regulations on transfer pricing, current OECD guidelines and methods that are based on the “arm’s length” applied in determining the price of transactions between related parties, meet in a professional way needs I realistic expectations of clients.
Access to the Study on transfer pricing, which, in accordance with these guidelines, the Act and the Regulations apply, based on:
– testing and analysis of your business with related parties, which includes a detailed overview of all inter-company agreements and treaties, as well as documents on the basis of which were conducted transactions;
– Select the appropriate method based on which each transaction is analyzed whether it was carried out in accordance with the principle of “arm’s length”, or whether the contract price in accordance with market or depart;
– Depending on how your business in the comparability of prices and margins realized primarily will be determined based on internal documents, both internal comparability of the data has the advantage with the tax authorities. However, if you only do business with related parties, in this case it is necessary to externally poređenjekorišćenjem foreign databases such as Amadeus database;
– If any mutual loans or credits, part of the study is to check the cost of interest and whether it was “thin capitalization” is the first step and the second, checking whether sukamatne rates in line with market conditions;
– After completing a detailed analysis and application of appropriate methods for determining whether your prices and margins in line with market prices, following the conclusion of which will be explained to you your duty correction porezive base the profit on the basis of transfer prices or not.
In accordance with professional standards, report on istudiji transfer prices, contains the following elements:
1. Analysis of the group of related parties which the taxpayer
2. Analysis of the industry
3. Functional analysis
4. The choice of methods for checking compliance of transfer prices with prices established on the principle of “hands vandohvata ”
The aim of our company
aim of our company is that, applying international auditing standards of the International Accounting Standards and the latest global methodology for performing these services meet the needs in a professional manner and realistic expectations audit clients to achieve their goals.
The founders of the company
Rosh Audit is a young company, derived from the joint efforts of its founding partners (more on this in the section: Personnel), who recognized the need to hit the market company whose task will be primarily communication with companies of different activities that have in us flexible advisors ready to provide them with professional advice on their accounting system and internal controls throughout the year.