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Spectrum of services in the sphere of transfer pricing
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Competence as a basic value
Methodology
An arsenal of methods for pricing and analysis of wide range of products and services.
Competence
Over 10 years AIM has cooperated with transnational corporations in various industries and markets.
Over
1200
packages of Transfer Pricing documentation
Responsibility
We guarantee timely preparation of the documents and defend a client’s interests during tax audits.
Reliability
We use trustworthy sources of information such as Ruslana, Spark, State statistics, and specialized periodicals - MetalBulletin, Platts, RoyaltyStat and others.
Projects by type of activity
Trading
47
Retail
Wholesale
Manufacturing
8
Services
7
Finances
10
Loans
Lease
Comparison methods for transfer pricing
projects45
Comparable Uncontrolled
Price Method (CUP)
Comparable Uncontrolled Price Method (CUP)
We compare the price charged for the goods within our controlled transaction with a range of market prices charged for identical goods in comparable transactions.
projects12
Transactional Net Margin Method (TNMM)
Transactional Net Margin Method (TNMM)
We compare the net margin earned in controlled transaction with net margin in comparable uncontrolled transactions or for independent companies operating in a way which is comparable to the taxpayer’s operation within the scope of controlled transaction.
projects32
Resale Price Method (RPM)
Resale Price Method (RPM)
We compare the price of controlled transaction and the market price: we compare the gross profit margin of controlled transaction with the market range of gross profit margin.
projects11
Cost Plus Method (CPM)
Cost Plus Method (CPM)
We compare the price of controlled transaction and the market price: we compare the gross profit margin of the prime cost earned in controlled transaction with the market range of the gross profit margin of the prime cost.
projects0
Profit Split Method (PSM)
Profit Split Method (PSM)
We allocate to every affiliated company involved in controlled transaction a portion of the total profit resulting from transaction which non-affiliated company would receive when participating in comparable uncontrolled transaction.
Number of projects by industries
Equipment and machinery
10
To industries
Equipment and machinery
10
List of major industries
Medical equipment
Climatic equipment
Electricity
Electricity
List of additional industries
Pumps and accessories
Uninterruptible Power Supply
Electric motor, servomotors
Technological and production equipment for metallurgical production
Manufacturing
42
To industries
Manufacturing
42
List of major industries
Building materials
Cosmetics and perfumery
Chemical Industry
Metallurgical Products
Medical supplies
Other
List of additional industries
Insulation, Roofing, Construction chemistry
Polymers, products made of polymers
Ceramics,
tile
Materials for advertising production
Perfumery and cosmetic products
Liquefied gas
Sealants
Plants protecting tools
Metallurgical Products
Metal Rolling
Aluminum products
Metal products
Automotive Industry and Special transport
4
Automotive Industry and Special transport
To industries
4
List of major industries
Tires
Parts for vehicles
Vehicles
List of additional industries
Trucks
Construction and Real Estate
2
Trading equipment
1
ІТ / Software /SaaS
1
Finance, Banking, Insurance and Fintech
12
Finance, Banking, Insurance and Fintech
To industries
12
List of major industries
Banking services
Activities in the financial services and insurance
List of additional industries
Loans
Logistics
Lease
Food industry, agricultural products
4
Food industry, agricultural products
To industries
4
List of additional industries
Corn
Seed
Confectionery
Healthcare and Pharmaceuticals
2
Get ready made Tranfer Pricing documentation in two weeks
Describing a tax payer’s activity
Identification of controlled operations; confirmation of their conformity to the law; detailed market description.
Describing a tax payer’s activity
1. Description of a controlled operation 2. Description of the market where a tax payer operates
Describing the group of companies
Description of the organisational structure of the group of companies; their activity; a list of the group’s competitive advantages.
Description of the Group
1. The Group’s property structure including persons who influence pricing 2. A list of persons which made a controlled operation 3. The Group’s main competitive advantages
Selecting a transfer pricing method
Selection of transfer pricing methods
1. Description of pricing on controlled operationsх 2. Selection of a transfer pricing method according to art.39 of Tax Code of Ukraine: 2.1. The CUP Method 2.2. The Resale Price Method 2.3. The Cost Plus Method 2.4. The Transactional Net Margin Method 2.5. The Transactional Profit Split Method 3. Information sources 4. Approach to economic analysis 5. Conclusion
Functional analysis
Functional analysis (separately for each kind of controlled operations and kind of contract)
1. General information 2. Description of main functions of Buyer and Supplier 3. Description of main risks of Buyer and Supplier 4. Conclusion on the results of functional analysis
Defining a market range of prices / profitability
Defining a market range of prices / profitability
1. Description of the approach to the application of the CUP method / net profit 2. Calculation of the market range of profitability according to the provisions of Tax Code of Ukraine 3. Making primary selection 4. Analysis of comparativeness of internal operations on key factors 5. Application of corrections to provide comparativeness of operations 6. Checking comparativeness criteria manually 7. Calculation of the market interval of prices / net profitability 8. Conclusion
Ready made package of documents
+ bonus offer
Price monitoring FREE of charge
of goods and services during a year
Consulting
on Transfer pricing issues
Documentation support
during the period of legal limitation
BONUS
for ordering a package of transfer pricing documentation
Our clients recommend us
In agribusiness
In automobile industry
In construction sector
In engineering system sector
In the sector of industrial equipment
In packaging industry
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