Transfer pricing

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 provide the following services in particular:

Potential risk assessment

We assess potential risks of transfer pricing for individual transactions.

Advisory and method selection

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.

Expert opinion

We can prepare expert opinions in cooperation with our expert institute.

Documentation for foreign entities

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.

CbCR - Country by Country Reporting

We prepare and file forms for Country by Country Reporting.

Binding assessments

We prepare binding assessments based on our clients’ request.

Contracts with associated entities

We draft or review contracts with associated entities.

Representation during tax audits

We justify transfer pricing and represent our clients during local or international tax audits.

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