Transfer pricing

Transfer pricing

Business with related parties requires timely tax analysis and transfer pricing documentation — before the transaction becomes subject to audit.

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Parent company
Branch
Owner
Related company
KCM analysis
Documentation
Tax risks
Recommendations
What collaboration looks like
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Related parties
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Analysis
03
Risks
04
Documentation
01
Identification of related parties
We determine which parties and transactions fall within the scope of transfer pricing.
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Who are related parties?

We explain who is considered a related party and which transactions are subject to transfer pricing analysis.

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What is transfer pricing?

Transfer prices are prices in transactions between related parties that must reflect arm's-length conditions.

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Most common transactions

Sales of goods, services, loans, licensing, and other transactions between related parties.

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Transfer pricing does not begin with preparing a report

Before documentation, a business, transaction, and tax risk analysis is needed — only then is the appropriate approach defined.

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When does the obligation arise?

The obligation to document and report arises when related-party transactions exist above prescribed amounts.

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Why is transfer pricing linked to accounting?

Transfer pricing analysis is based on accurate data from business records and financial statements.

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Loans between related parties

Interest rates, terms, and loan conditions must be in line with market practices.

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Business with related parties abroad

We connect transfer pricing with international regulations and the tax treatment of transactions.

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Benefits of collaboration

Why do companies engage KCM?

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Many years of experience in tax advisory
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Tax advisory and accounting in one place
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Legal support in complex transactions
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Team of tax advisors and accountants
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Experience with international transactions
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Support in preparing documentation
Frequently Asked Questions

Frequently Asked Questions

Must every company have transfer pricing documentation?
The obligation depends on the type and scope of related-party transactions. Even when no formal obligation exists, risk analysis and price alignment with arm's-length conditions are recommended.
Which transactions are most commonly analysed?
These most commonly include sales of goods and services, loans, licensing, management services, and other transactions between a parent company, branches, owners, and related entities.
When is documentation required?
Documentation is prepared before or in parallel with transactions subject to transfer pricing, not only after the Tax Administration initiates an audit.
Do transfer pricing rules apply to smaller companies too?
Yes. The rules apply based on relatedness and the type of transaction, not solely on company size.
Do you provide support during tax audits?
Yes. We assist with preparing documentation, communicating with the Tax Administration, and representation in transfer pricing proceedings.

Not sure whether you have transfer pricing obligations?

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