Transfer pricing services between Sweden and Russia
Transfer pricing between Russian and foreign Group companies, e. g Swedish, requires expert knowledge in Russian tax reporting. Russian companies having transactions with related foreign entities (so-called controlled transactions) must submit particular documents to the Russian tax authorities for verification of the prices they use in such transactions. If the prices are not in line with the market level, this could indicate an understatement of payable taxes. With our colleagues in Russia we can help you handle this correctly. See process described below.
Identification of related entities and controlled transactions
- Basic analysis of agreements between related entities and accounting data of the company for identification of transactions between related entities
- Determination of shares of participation and/or other types of control between related entities based on analysis of organization charts, articles of associations, documentation of shareholders meetings and other available information concerning related entities.
- Testing of accounting data of the company for determination of controlled transactions based on sum and qualitative criteria, including controlled transactions with Russian and foreign entities.
- Application of special tests and questionnaires for obtaining information necessary for identification of controlled transactions.
- Written report to the client concerning need of declaration of controlled transactions in a particular year.
Business overview and analysis of commercial and financial conditions of controlled transactions
Selection of applicable Transfer Pricing-method
- Study of business scheme and intercompany relationships in the Group.
- Detailed analysis of intra-group agreements for determination of factors affecting transfer pricing, including analysis of functions, liabilities and risks of the parties to the transactions, allocation of assets, etc.
- Review of primary documentation and accounting data concerning controlled transactions for verification of features of actual execution of agreements
- Estimation of impact of controlled transactions on tax burden of the client in a particular year.
- Selection of applicable Transfer Pricing-method.
- Written report to the client about chosen Transfer Pricing-method and the way of its application.
Comparative analysis of transfer prices
- Check for availability of information about market prices for comparable transactions in the public sources of information listed in the Tax Code of RF. Selection of the information source.
- Search, check, selection and processing of statistical data about market prices/profitability which is suitable for comparative analysis.
- Calculation of market interval of prices/profitability.
- Calculation of financial indexes of the company needed for comparative analysis of profitability.
- Comparative analysis of company’s transfer pricing according to the chosen Transfer pricing-method.
- Report to the client on market interval of prices/profitability and correspondence of client’s transfer prices/profitability to the market level.
Preparation of Transfer Pricing Documentation update
- Identification of related parties and controlled transactions
- Business overview and analysis of commercial and financial conditions of controlled transactions. Selection of applicable TP-method.
- Comparative analysis of transfer prices by chosen Transfer Pricing-method
- Preparation of Transfer Pricing Documentation according to the requirements of Tax Code, including:
- Information about parties to controlled transactions, their functions, assets used, economic/commercial risks taken
- Description of controlled transactions, their conditions and methods of pricing
- Information about factors which influence transfer pricing in controlled transaction
- Data about incomes/costs related to controlled transactions
- Justification of Transfer Pricing-method applied for determination of taxable incomes in controlled transactions and information about used sources of information for identification of market prices/profitability
- Comparative analysis of transfer pricing by Transfer Pricing-method and conclusions
- Information about the tax adjustments made by the company
Accountor can help you in 7 countries
Accountor can help you with everything from setting up a company, pay salaries, to make closing and consolidations. We are one of Northern Europe's largest full-service agencies in the financial services industry. In addition to in Sweden we can help you in the following countries: Finland, Norway, Denmark, Netherlands, Russia and Ukraine. Do not hesitate to contact us.