EBS offers the following services in the area of transfer pricing:
- detection of controlled transactions (free of charge);
- preparing of transfer pricing documentation files;
- benchmarking (the service may be provided without preparing of transfer pricing documentation in case the documentation is prepared by the customer);
- advising on transfer pricing issues;
- providing of methodological support for TP documentation preparation in case the documentation is prepared by the customer;
- transfer pricing policy elaborating;
- filing a report on controlled transactions.
Preparing of transfer pricing documentation is performed in accordance with the requirements of the Tax Code of Ukraine, acts of the Government of Ukraine, acts of the Ministry of Revenues and Duties of Ukraine, other ministries and agencies as well as considering the provisions of the OECD TP Guidelines and UN Practical Manual on TP.
The process of transfer pricing documentation preparation includes the following stages:
Stage 1: Overall analysis of a controlled transaction and analysis of parties of the transaction:
- overall analysis of the controlled transaction;
- analysis of parties of the transaction, analysis of a group of companies, which includes parties of the controlled transactions;
- analysis of comparable transactions carried out by one of the parties of the controlled transaction with persons who are not recognized as associated enterprises (if any);
- analysis of pricing method adopted by the parties of the transaction, as well as analysis of any bonuses or discounts given by one of the parties (if any) and analysis of factors, which influenced on the price setting in the transaction.
Stage 2: FAR study and methodological approach development to economic analysis:
- analysis of functions, assets and risks of the parties of the transaction (FAR study);
- choice of the tested party of the transaction for economic analysis purposes;
- applicable TP method determination;
- determination of the time interval, the sources of information, signs of compatibility for economic analysis purposes.
Stage 3: Economic analysis:
- analysis of profitability of the controlled transaction (in the case of application of the resale price method, “cost plus” method, or net margin method);
- benchmarking study, including benchmarking based on databases provided by Bureau Van Dijk;
- determination of the market range of transactional profitability.