Restructuring from a Transfer Pricing Perspective
Transfer pricingGroup restructurings—encompassing changes in business character, the nature of transactions, or the roles and status of entities within a multinational...

Transfer pricing has no longer been a domain of multinational groups, but has become an integral part of reviews performed by local tax administrators. Based on the recent actions of tax administrations, it is obvious that this area has become globally perceived as crucial for tax audits because of suspected tax evasions as well as for the financial management of the company groups in terms of a tax liability impact, due care and the interest of company shareholders. Insufficient preparation often becomes a source of extreme and unexpected complications during a tax audit and leads to major implications for taxpayers’ further existence. On the other hand, a proactive approach to transfer pricing often optimises not only the setup of a company group’s current financial management thanks to reviewed goods and service flows but also the setup of license and interest payments.
We assess potential risks of transfer pricing for individual transactions.
We provide advisory services in selecting the appropriate method of transfer pricing for transactions with associated entities.
We prepare a group’s transfer pricing documentation in the form of Master File and Local File for each relevant country.
We can prepare expert opinions in cooperation with our expert institute.
We provide transfer pricing documentation for foreign entities and find out specific rules and local requirements for relevant countries in cooperation with Grant Thornton branch offices.
We prepare and file forms for Country by Country Reporting.
We prepare binding assessments based on our clients’ request.
We draft or review contracts with associated entities.
We justify transfer pricing and represent our clients during local or international tax audits.
Group restructurings—encompassing changes in business character, the nature of transactions, or the roles and status of entities within a multinational...
The Supreme Administrative Court (SAC) addressed a dispute between a Czech automotive company and the tax authority regarding an additional income tax...
Last year, we informed you about the conclusions of the CJEU in Case C-726/23 (Acromet Towercranes), where the Court considered an additional payment by a...
At the end of 2025, the Ministry of Finance of the Slovak Republic issued a new Guideline on determining the content of transfer pricing documentation (No....
In its judgment 3 Afs 23/2024–60 of 29 October 2025, the Supreme Administrative Court (SAC) confirmed that Section 23(7) of the Income Tax Act also applies...
In April this year, we drew your attention to the opinion of the Advocate General of the Court of Justice of the European Union in Case C-726/23 and to the...
There is frequent discussion within the EU as to whether distributors’ remuneration, which is typically expressed as a margin on sales, also includes license...
In judgment 1 Afs 2/2025-54, the Supreme Administrative Court (SAC) addressed the question whether the cost of materials should be included in the cost base...
Given the fact that many Czech tax entities have their parent companies or other related parties in Germany, we would like to draw your attention to the...
In light of the recently published opinion of the Advocate General of the CJEU in Case C-726/23, we are revisiting the issue of the VAT treatment of profit...