TRANSFER PRICING

Nowadays we live in a complex and globalized economic environment in which the number of transactions between related parties increases day by day, and therefore the demands of the Tax Authorities also increases in order to obtain more transparency regarding such transactions.

Therefor, this new scenario of complexity requires an expertise that allows aligning the transfer pricing policy with each company’s business strategy and to avoid tax risks that may exists with the related party transactions.

In this sense, DILIGENS has transfer pricing experts that help each client to build comprehensive strategies allowing to achieve its international and operational objectives.

On international services, DILIGENS has a network of TP experts, located in different countries, to cover any services required by our clients.

In this regard, it shall be remarked the worth of a correct planning for all companies willing to be established in our country, specially within low taxation areas like the Special Canary Islands Zone (ZEC), which offers important tax benefits for companies that, under certain requirements, are based in the Canary Islands.

The main transfer pricing services provided by DILIGENS are:

• Advisory for the design and planning of transfer pricing policies, with the aim of improving the tax efficiency of the companies.
• Preparation of the transfer pricing documentation, either for national or International companies, complying with the local regulation of each country.
• Preparation of the documentation for the application of APAs with the Tax Authorities, together with the corresponding negotiations.
• Benchmarking studies, with the aim of establishing the pricing in the related-parties’ transactions at arm’s length.
• Review of the tax picture of the company, detecting potential risks in terms of transfer pricing and designing the relevant recommendations to avoid the tax contingencies detected.
• Advisory and assistance with the filling out of the 231 Form – Country by Country report and 232 Form – Statement of related-parties’ transactions and transactions involving tax havens territories.
• Assistance with the tax inspections for transfer pricing.
• Review of agreements between related parties, from a transfer pricing perspective.
• Assessment of the customs value for International trading transactions between related-parties.