Companies that conduct transactions with related parties or with companies resident in tax havens fall within the scope of transfer pricing regulations and must demonstrate to the tax authorities that the agreed-upon prices comply with the arm’s-length principle, that is, these transactions must be conducted under the same terms, conditions, and prices as those carried out between independent parties. Currently, a high percentage of business transactions occur between companies within the same corporate group, leading the tax authorities to establish stricter rules to optimize tax compliance; therefore, companies must be prepared to ensure proper compliance with transfer pricing regulations.
Casahierro Consultores has a multidisciplinary team with solid technical knowledge and extensive experience in transfer pricing and consulting. We offer a comprehensive, holistic approach aimed at generating value in business and corporate activities, as well as ensuring formal compliance with the Tax Authority.
To deliver our services, we have selected the best tools and databases to meet the level of detail required for analyzing and preparing transfer pricing reports, such as Standard & Poor’s’s Capital IQ platform, a powerful source for accessing a variety of financial data and reliable public information on companies and markets worldwide; and the Royalty Range database, a tool for benchmarking royalty rates and service fees, used for comparative studies via the direct CUP method.
Our services include:
- Preparation of the Technical Transfer Pricing Study
- Development of the Market Range Study – Benchmarking
- Preparation of BEPS Reports: Informative Affidavit, Local Report, Master File, and Country-by-Country Report
- Preparation of the Informative Affidavit on Transfer Pricing
- Preparation of the Profit Test – Intragroup Services
- Advice on tax audits or litigation related to compliance with transfer pricing rules
- Drafting of Intercompany Agreements
