Diagnosis of TCE risks
Risk diagnostics are a service of tax consultant from AGTL Kharkiv, Kyiv, Odessa.Our experts will help you to identify the risks you have, build the optimal market price control structure and take on all the problems associated with communication with the tax authorities on the issue of controlled transactions.
Due to the fact that there are still many legal gaps and inaccuracies in the regulation of transfer pricing rules, the interpretation of many rules is based only on the existing letters of the Ministry of Finance and the GFS of Ukraine. But despite the large number of such recommendations, many questions remain unactured, in addition, some of the letters contradict each other. Judicial practice cannot help in interpreting transfer pricing rules – at the moment it has not been formed yet.
Risks of TC
At the moment, TC is one of the riskiest institutions of tax law in terms of additional charges by tax authorities, because the more gaps and inaccuracies in the legislation, the more complicated the pricing procedure itself, the more likely it is that the tax inspector and the taxpayer will have different interpretations of the same rule. Meanwhile, fines for violation of TCE rules are currently the largest in tax law.
We work with convenient forms of queries for you and in a format that is convenient for you, for example:
- Analysis of individual contracts and transactions between interdependent persons;
- Analysis and setting up the transfer pricing control system for the company as a whole;
- Guidelines for checking data on counterparties to avoid risks under TC;
- Analysis and modification of the relationship structure between interdependent persons to minimize risks under the TC;
- consultations on individual tax law issues within the TC.
We work with both Ukrainian enterprises and their foreign elements. We are ready to help you to draw up documentation about the market price and confirm it, accompany the transfer pricing check or defend your interests in court.
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We will advise you, help you organize accounting support, choose a tax system, and if necessary – check the processes of organizing your business on legal, accounting, tax, as well as financial issues. And believe me, your money will certainly come back to you.
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Call! +38 (050) 676-34-45, +38 (098) 028-08-51.