We can provide specialist advice and assistance on complex transfer pricing matters. Global organizations are operating in an environment of unprecedented challenges and changes. The increasing volume of intercompany transactions combined with more rigorous enforcement efforts on the part of tax authorities worldwide have made transfer pricing a substantial compliance priority for organizations engaged in cross-border transactions. Cyprus will be implementing detailed transfer pricing rules in 2017. Our firm can help clients meet the new compliance requirements by introducing practical transfer pricing solutions into their overall global business operations and objectives, assist with the preparation of documentation to support their transfer pricing practices, and to represent clients before authorities and courts for the purposes of resolving disputes. In particular, in the context of the imminent implementation of transfer pricing rules in Cyprus, our team will be in a position offer specialist advice and assistance with the following matters:
- Transfer Pricing Planning and Documentation
Our transfer pricing professionals can assist taxpayers with the preparation of comprehensive transfer pricing documentation and reports to reflect the commercial nature of their intra-group pricing strategies and decisions. We can also assist global groups to prepare cross-border documentation satisfying all of their documentation requirements in an efficient manner.
- Advance Pricing Agreements (APAs)
Our transfer pricing professionals can assist clients with all aspects of supporting their transfer pricing strategies before the relevant tax authorities. We can also assist with applications for double tax relief through the tax treaty competent authority process and help clients submit applications to obtain Advance Pricing Agreements (APAs) with the tax authorities for the purposes of pre-agreeing and arriving at acceptable transfer pricing arrangements.
We offer representation and professional assistance with disputes in relation to transfer pricing strategies.