YOUR TRANSFER

PRICING PROJECT...

a walk in the park!?...

we've got what it takes
to make it happen!

How it Works

You pick & choose what you need

BENCHMARKING
STUDIES

Depending on your project, we can deliver precisely customized benchmarking studies, either OECD-compliant, or designed to meet local authorities’ requirements. Our data sources are all the major databases, from which we manually select and verify each individual comparable entity / transaction that will make it into the final study, thus ensuring excellent quality of the sample. The outcome of our work will be a replicable read more and auditable study, which will successfully pass the scrutiny of the fiscal authorities’ controls.

We deliver the following types of benchmarking studies: Profit-level indicators/ Interest rate / License fees / Any others you may have in mind – we can assist you!

Check out here a more extensive list of projects we recently delivered.

Price range of benchmarking studies: EUR 500 to EUR 3,000.show less

TRANSFER PRICING MAN-HOURS

If a helping hand (or more) with your project is what you require, we can lend you some! Transfer pricing man-hours to be delivered by members of our team, on different seniority levels, depending on your choice / complexity of your project:
CONSULTANTS (up to 3 years of thorough transfer pricing working experience);
SENIOR CONSULTANTS (3 to 7 years of read more extensive transfer pricing experience, ADIT-certified professionals);
EXPERTS (7+ years of experience, your “go-to” professionals that have the experience, knowledge and sourcing capabilities to respond to any transfer pricing issue you may have);
SENIOR ADVISORS (15+ years of experience).

Range of our hourly rates: EUR 30/hour up to EUR 180/hour. For Senior Advisors - EUR 250/hour.show less

ALL THINGS TRANSFER PRICING

For all your other transfer pricing needs, our fantastic team will most likely be able to help you out. We cover the full range of transfer pricing - related work:

  • TP design and planning
  • TP documentation (Master file and local file)
  • TP reviews
  • Benchmarking studies
  • Country by country reporting (CbCR)
  • TP due diligence
read more
  • Advance pricing arrangements (APAs)
  • Audit defense
  • DAC 6 review (EU mandatory disclosure rules)
  • TP training
  • FIN 48
show less

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WORK WITH US

AND you might as well...

FORGET ABOUT DATABASES

We perform 300+ benchmarking studies a year for a wide range of intra-group transactions. We have access to and experience with all major databases used for these studies. No more manual search and data crunching for your team, we do it all.

GROW YOUR BUSINESS, NOT YOUR PAYROLL

Deliver more TP projects and/or manage more complex TP assignments, while we supply the extra man-hours you need, at the level of seniority required by your project.

ESCAPE THE ROUTINE WORK

Focus your capabilities on strategic issues or simply claim back your personal time! We take care of your routine TP work.

INCREASE YOUR PROJECT’S PROFITABILITY

You can get from us the TP resources you need at highly competitive fees. Result: the profitability of your project increases as you subcontract work with us and retain the cost savings.

WHO WE ARE

Your Partner for Transfer Pricing Safety

is a platform powered by Transfer Pricing Services (TPS), the leading independent transfer pricing consultancy firm in Central and Eastern Europe. Established in 2009, TPS was awarded the titles of “Central European Transfer Pricing Firm of the Year” and “Best Transfer Pricing Team in Romania” by various organizations during 2011 - 2019. It currently serves more than 500 clients, across all industry segments and sizes. Check out a list of project types we worked on here.

The main objective of platform is to assist businesses with managing their transfer pricing risk and optimize the related workload. We aim to do so by delivering excellent transfer pricing assistance and outsourcing tools in a consistent and cost conscious manner.

We rely on our worldwide alliances with transfer pricing specialists and our core team of ADIT/ ACCA-qualified, 30+ full-time professionals. Thus, we are able to come up with timely and practical solutions tailored to the specifics of over 60 fiscal jurisdictions.

CLICK here for
DAC6 EU Member States Implementation:
Updated Country-by-Country Guide

DAC6 – Updated Country by Country Guide

The DAC6 compliance requirements of each global business vary from country to country.

Not all EU member states have yet finalised their guidance and additional details, such as legal professional privilege and penalties vary between each state. To help firms save time and money on conducting their own research, VinciWorks has collaborated with Transfer Pricing Services to create a concise country-by-country guide to DAC6 compliance. The guide can be purchased either together with our DAC6 compliance solution or as a standalone tool.

What is included in the country-by-country guide?

Tax Authority and Legislation

This section includes the name and contact details of the national tax authority and a link to the locally implemented DAC6 legislation, together with additional guidance where available. The current status of the legislation is also listed, including the date of publication and details of any expected legislative amendments.

Form of Reporting

The information reported to each EU Member State will be contributed to a central EU directory accessible by the competent tax authorities. This section looks at the form of reporting, including the reporting language required and any timelines that deviate from the EU Directive.

Tax Authority and Legislation

This section includes the name and contact details of the national tax authority and a link to the locally implemented DAC6 legislation, together with additional guidance where available. The current status of the legislation is also listed, including the date of publication and details of any expected legislative amendments.

Form of Reporting

The information reported to each EU Member State will be contributed to a central EU directory accessible by the competent tax authorities. This section looks at the form of reporting, including the reporting language required and any timelines that deviate from the EU Directive.

Legislative Details

This section includes details of the types of taxes covered by local DAC6 legislation, and details where these have a wider scope than the EU Directive, such as domestic arrangements or details of additional hallmarks.

Penalties

Under the EU Directive, each EU Member State can lay down their own rules on penalties; however, these must be effective, proportionate and dissuasive. This section explains the types and ranges of penalties implemented under national laws.

Main Benefit Test

Under the EU Directive, the definition of main benefit test is very broad. This section includes local interpretations of the main benefit test and definitions of tax advantage in each EU Member State.

Additional Guidance

This section includes links to the guidelines, opinions, explanatory memorandums and other legislative documents released by EU Member States that are important for providing clarity on local implementation.

Legal Professional Privilege (LPP)

Under the EU Directive, each EU Member State has a right to take the necessary measures to exempt reporting when legal professional privilege applies under national laws. This section investigates the LPP exemption in each EU Member State.

What is new in the updated country-by-country guide?

1. Direct links to all available EU Member State legislation, allowing you to collect DAC6 information in each jurisdiction directly from the source.

2. Clear definitions of the “main benefit test” and “tax advantage” in each EU Member State. This is critical information in order to make accurate determinations for reporting in each jurisdiction.

3. Updated details of legal professional privilege exemptions including scope and limitations.

4. Up-to-date information about forms of reporting, including languages and reporting formats.

5. Additional guidance section with direct links to correspondences, consultations, explanatory memorandum, draft laws and opinions.
6. This concise country-by-country guide is the only guide of this nature available.

WHAT PEOPLE SAY

ABOUT US

I’ve been working with the guys at TPS for the past 9 years. That’s a long time and lots of projects – APAs, TP documentation files, TP disputes, just to name a few. They are really quick to “get it” and quick to respond. Deadlines met, qua...read more

Andrei Ianache

Head of Taxes

OMV Petrom SA

Here at Bitdefender there is a lot of business going on in multiple countries, many markets – and as many fiscal landscapes! TPS is taking care of the transfer pricing documentation across our many jurisdictions and definitely made life easier arou...read more

Niculae Dinca

Finance

Bitdefender

TPS is a trusted business partner, assisting on all transfer pricing matters related to our Group operations. We appreciate their great expertise in the field, business understanding and especially the added value input and tailor-made solutions they...read more

Adela Tapurin

Group Tax & Finance Director

NEPI Rockcastle

We chose TPS in 2010 and since then we’ve built together a strong professional relationship. If you look for flexibility, business understanding, client aproach and long term reliable partner, then TPS is the right choice!

Ene Magdalena

Financial Manager

Gebruder Weiss

I am definitely satisfied with the quality of the TPS work. They are prompt, always available - including senior people, which is great because things get done nice and easy! I appreciate they are really serious about their business and “in” for ...read more

Mariana Marin

CEO

Strabag BRVZ SA

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Types of projects we delivered

  • Pricing and documenting the arm’s length margin for management activities
  • Pricing and documenting the arm’s length margin for advisory and sub-advisory investment activities
  • Pricing and documenting the arm’s length margin for handling activities (i.e. loan management activities) by reference to annual fees charged in syndicated loans
  • Pricing and documenting the arm’s length margin for back to back loans, including the handling fee remuneration
  • Pricing and documenting the intra-group interest rate for loans of various tenors, levels of security, fixed and floating interest rates
  • Estimating the synthetic credit rating for tested borrowers (with and without implicit parental support)
  • Determining the arm's length debt capacity (gearing ratio) of the tested borrower
  • Designing, pricing, documenting and implementing all facets of a house bank or cash pooling structure
  • Pricing intra-group guarantee fees related to third party senior bank loans
  • Pricing and documenting intercompany performance-related (i.e., non-financial) guarantee fees
  • Pricing and documenting money market deposits and FX transactions
  • Pricing and/or adjusting for unique intercompany loan characteristics
  • Pricing an arm's length factor rate in several receivables factoring transactions
  • Determining the arm’s length sale price of loan/portfolio of loans
  • Pricing and documenting the arm’s length royalty rate for different types of licensing activities.
  • Pricing and documenting the remuneration to be earned by an intermediary licensing company for the risks incurred with the sublicensing activities
  • Full transfer pricing documentation projects for financial intermediation activities, where the risk is both limited and unlimited
  • Determination of the appropriate return on equity by using the CAPM model
  • Pricing and documenting the arm’s length fee for acquisition services
  • Pricing and documenting the arm’s length fee for financing services
  • Pricing and documenting the arm’s length fee for strategic asset management services
  • Pricing and documenting the arm’s length fee for asset management services
  • Pricing and documenting the arm’s length fee for the property management services
  • Pricing and documenting the arm’s length fee for marketing services
  • Pricing and documenting for electricity supply transactions
  • Determining the rent for various types of properties (e.g. office, retail, residential, industrial) / equipment
  • Determining the split of the fee to be earned by two or more inter-connected service providers by performing a contribution analysis
  • Pricing and documenting the bunkerage services
  • Pricing and documenting franchise fees for various businesses
  • Pricing and documenting the arm’s lenght margin for various types of services and activities
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