Transfer pricing

Transactions within groups of multinational or local companies have a strong effect on results and thus the tax liabilities of individual entities. The Czech tax administration therefore considers transfer pricing a priority. Based on our current experience, transfer pricing audits are a rule rather than an exception – and underestimating transfer pricing or failing to document it properly will often result in a difficult and lengthy defence during a tax audit. Consequences can include additional tax assessments, penalties, late-payment interest and even negative publicity.

The importance of transfer pricing is also growing in connection with the OECD’s action plan known as BEPS (Base Erosion and Profit Shifting).

Our team

We can support you in potential disputes – where timely handling of both substantive and procedural arguments is required – but also right from the start, helping you set up and implement intra-group business models and transactions in a way that gives the tax authority no reason to challenge them later. We will prepare transfer pricing documentation for you or file a request for a binding assessment of transfer pricing with the tax office on your behalf. In subsequent dealings with the tax authority, our experienced experts will be ready to support you both in local disputes and in cross-border arbitrations.