AIM
3 Sholudenka st., office 310 04116 Kyiv, Ukraine
+380442909435 info@aimarketing.info
Main Services Transfer Pricing

Preparation of the TP documentation set


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of unpredicted extra tax fees.
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Spectrum of services in the sphere of transfer pricing

I need consulting on Transfer Pricing
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I need market analysis for the Transfer Pricing report
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I need calculating financial indicators
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I need help in preparing a report on controlled operations
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I need a full package of Transfer Pricing documentation
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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
90
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.
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Projects by type of activity
Trading
47

Retail

Wholesale

Manufacturing
8
Services
7
Finances
10

Loans

Lease

Comparison methods for transfer pricing
projects 45
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.
projects 12
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.
projects 32
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.
projects 11
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.
projects 0
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

05 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

01 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
04 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
01 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
01 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
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Price monitoring FREE of charge
of goods and services during a year
Consulting
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Documentation support
during the period of legal limitation
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Blog
Changes in the List of Countries from Low Tax Jurisdictions
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ONLINE CALCULATION OF TRANSFER PRICING DOCUMENTATION COST
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The whole truth about additional accruals in transfer pricing reporting
Your Controlled Transactions Report and transfer pricing (TP) documentation are in order. However, this may st...
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What you should know about stock quotes when preparing transfer pricing documentation
The case where the transfer pricing method is clearly defined. Vital information for exporters and importers.
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HOW TO CORRECT ERRORS IN CONTROLLED TRANSACTIONS REPORT?
HOW TO CORRECT ERRORS IN CONTROLLED TRANSACTIONS REPORT?
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Transfer Pricing Penalties - 2018
What are the PENALTIES for the failure to submit or untimely/incomplete submission of Controlled Transactions...
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How to Avoid Getting Dragged into Litigation with the Tax Authorities Due to the Transfer...
How to Avoid Getting Dragged into Litigation with the Tax Authorities Due to the Transfer Pricing? The help of...
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Comparison Methods in Transfer Pricing
Comparison Methods in Transfer Pricing
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Who Is Required to Submit Controlled Transactions Report and Prepare Transfer Pricing Docu...
Who Is Required to Submit Controlled Transactions Report and Prepare Transfer Pricing Documentation?
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How to avoid pain in the neck triggered by 2017 transfer pricing?
How to avoid pain in the neck triggered by 2017 transfer pricing?
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Completed projects

Building materials and other products
Methods :
  • The method of net profit
  • The method of comparative uncontrollable price
4
Completed projects
More →
Building materials and other products
Product nomenclature :
TP_NOMENCLATURE_25
TP_NOMENCLATURE_45
TP_NOMENCLATURE_46
TP_NOMENCLATURE_73
Operation type
Import
Export
← Back
Building insulation materials and products
Methods :
  • The method of net profit
  • Method of resale price
1
Completed projects
More →
Building insulation materials and products
Product nomenclature :
TP_NOMENCLATURE_249
Operation type
Import
← Back
Building Glass, glass products, translucent construction
Methods :
  • Cost-plus method
1
Completed projects
More →
Building Glass, glass products, translucent construction
Product nomenclature :
TP_NOMENCLATURE_68
Operation type
Import
← Back
Packaging
Methods :
  • Cost-plus method
  • The method of net profit
  • The method of comparative uncontrollable price
  • Method of resale price
3
Completed projects
More →
Packaging
Product nomenclature :
TP_NOMENCLATURE_43
TP_NOMENCLATURE_71
TP_NOMENCLATURE_252
Operation type
Import
← Back
Rubber and Plastics
Methods :
  • The method of comparative uncontrollable price
1
Completed projects
More →
Rubber and Plastics
Product nomenclature :
TP_NOMENCLATURE_69
Operation type
Import
← Back
Food
Methods :
  • The method of net profit
  • The method of comparative uncontrollable price
5
Completed projects
More →
Food
Product nomenclature :
TP_NOMENCLATURE_38
TP_NOMENCLATURE_39
TP_NOMENCLATURE_48
TP_NOMENCLATURE_247
NO_TRANSLATION
Operation type
Import
Export
← Back
Medical supplies
Methods :
  • Method of resale price
1
Completed projects
More →
Medical supplies
Product nomenclature :
TP_NOMENCLATURE_33
Operation type
Import
← Back
Cosmetics and perfumery
Methods :
  • The method of net profit
1
Completed projects
More →
Cosmetics and perfumery
Product nomenclature :
TP_NOMENCLATURE_62
Operation type
Import
← Back
Products of metallurgy
Methods :
  • The method of comparative uncontrollable price
  • Method of resale price
  • The method of net profit
4
Completed projects
More →
Products of metallurgy
Product nomenclature :
TP_NOMENCLATURE_44
TP_NOMENCLATURE_56
TP_NOMENCLATURE_60
TP_NOMENCLATURE_64
Operation type
Import
Export
← Back
Technological and production equipment
Methods :
  • The method of net profit
  • Cost-plus method
  • Method of resale price
3
Completed projects
More →
Technological and production equipment
Product nomenclature :
TP_NOMENCLATURE_23
TP_NOMENCLATURE_66
TP_NOMENCLATURE_248
Operation type
Import
Import and Export
← Back
Medical equipment
Methods :
  • The method of net profit
  • Cost-plus method
1
Completed projects
More →
Medical equipment
Product nomenclature :
TP_NOMENCLATURE_24
Operation type
Import
← Back
Ventilation and air conditioning
Methods :
  • Method of resale price
1
Completed projects
More →
Ventilation and air conditioning
Product nomenclature :
TP_NOMENCLATURE_251
Operation type
Import
← Back
Power engineering
Methods :
  • The method of comparative uncontrollable price
1
Completed projects
More →
Power engineering
Product nomenclature :
TP_NOMENCLATURE_77
Operation type
Import and Export
← Back
Banking services
Methods :
  • The method of comparative uncontrollable price
1
Completed projects
More →
Banking services
Product nomenclature :
TP_NOMENCLATURE_76
Operation type
Import
← Back
Software
Methods :
  • The method of net profit
2
Completed projects
More →
Software
Product nomenclature :
TP_NOMENCLATURE_13
TP_NOMENCLATURE_61
Operation type
Import
Export
← Back
Household appliances and machines
Methods :
  • Cost-plus method
  • The method of net profit
2
Completed projects
More →
Household appliances and machines
Product nomenclature :
TP_NOMENCLATURE_12
TP_NOMENCLATURE_55
Operation type
Import
Import and Export
← Back
Computers and accessories
Methods :
  • The method of net profit
  • Cost-plus method
1
Completed projects
More →
Computers and accessories
Product nomenclature :
TP_NOMENCLATURE_11
Operation type
Import
← Back
Telecommunication services
Methods :
  • The method of comparative uncontrollable price
1
Completed projects
More →
Telecommunication services
Product nomenclature :
TP_NOMENCLATURE_74
Operation type
Import
← Back
Non-residential buildings
Methods :
  • Method of resale price
  • The method of comparative uncontrollable price
2
Completed projects
More →
Non-residential buildings
Product nomenclature :
TP_NOMENCLATURE_59
TP_NOMENCLATURE_63
Operation type
Import
Import and Export
← Back
Vehicles
Methods :
  • The method of net profit
1
Completed projects
More →
Vehicles
Product nomenclature :
TP_NOMENCLATURE_29
Operation type
Import
← Back
Spare parts
Methods :
  • The method of net profit
  • The method of comparative uncontrollable price
2
Completed projects
More →
Spare parts
Product nomenclature :
TP_NOMENCLATURE_34
TP_NOMENCLATURE_41
Operation type
Import
Export
← Back
Trade in machines and equipment
Methods :
  • The method of net profit
  • Method of resale price
3
Completed projects
More →
Trade in machines and equipment
Product nomenclature :
TP_NOMENCLATURE_27
TP_NOMENCLATURE_28
TP_NOMENCLATURE_67
Operation type
Import
← Back
Trade in electrotechnical equipment
Methods :
  • Cost-plus method
  • The method of net profit
1
Completed projects
More →
Trade in electrotechnical equipment
Product nomenclature :
TP_NOMENCLATURE_36
Operation type
Import
← Back
Hightech, IT Hardware
Methods :
  • Cost-plus method
  • Method of resale price
1
Completed projects
More →
Hightech, IT Hardware
Product nomenclature :
TP_NOMENCLATURE_16
Operation type
Import
← Back
Chemical
Methods :
  • Cost-plus method
  • The method of net profit
1
Completed projects
More →
Chemical
Product nomenclature :
TP_NOMENCLATURE_37
Operation type
Export
← Back
Machine building and metal working
Methods :
  • Cost-plus method
1
Completed projects
More →
Machine building and metal working
Product nomenclature :
TP_NOMENCLATURE_9
Operation type
Import
← Back
Oil and gas
Methods :
  • The method of comparative uncontrollable price
  • The method of net profit
1
Completed projects
More →
Oil and gas
Product nomenclature :
TP_NOMENCLATURE_18
Operation type
Import
← Back
Metallurgical
Methods :
  • The method of comparative uncontrollable price
1
Completed projects
More →
Metallurgical
Product nomenclature :
TP_NOMENCLATURE_32
Operation type
Import
← Back
Forest
Methods :
  • The method of comparative uncontrollable price
1
Completed projects
More →
Forest
Product nomenclature :
TP_NOMENCLATURE_8
Operation type
Export
← Back
Agricultural
Methods :
  • The method of comparative uncontrollable price
  • The method of net profit
  • Method of resale price
9
Completed projects
More →
Agricultural
Product nomenclature :
TP_NOMENCLATURE_19
TP_NOMENCLATURE_21
TP_NOMENCLATURE_31
TP_NOMENCLATURE_35
TP_NOMENCLATURE_57
TP_NOMENCLATURE_58
TP_NOMENCLATURE_72
TP_NOMENCLATURE_75
TP_NOMENCLATURE_253
Operation type
Import
Export
Import and Export
← Back
Building Materials
Methods :
  • The method of net profit
  • Method of resale price
1
Completed projects
More →
Building Materials
Product nomenclature :
TP_NOMENCLATURE_70
Operation type
Import
← Back
Light industry
Methods :
  • The method of comparative uncontrollable price
  • Cost-plus method
  • The method of net profit
2
Completed projects
More →
Light industry
Product nomenclature :
TP_NOMENCLATURE_49
TP_NOMENCLATURE_65
Operation type
Import
Export
← Back
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