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

Controlled Operations Report


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Diagnosis of the presence of controlled operations
Calculation of operations with companies in the states from the List of the Cabinet of Ministers of Ukraine 977-p rule of the "extended hand"
Assessment of the risks of penalties and recommendations for their avoidance / minimization
Calculation of the conditions of controlled operations
A set of analytical procedures needed to select a pricing method and justify price levels in controlled transactions.
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
70
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
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

LANDING_TP_INDUSTRIES_TREE_TITLE

  • Medical equipment
  • Climatic equipment
  • Electricity
  • Electricity

LANDING_TP_INDUSTRIES_TREE_TITLE2

  • Pumps and accessories
  • Uninterruptible Power Supply
  • Electric motor, servomotors
  • Technological and production equipment for metallurgical production
Manufacturing
42
To industries

Manufacturing

01 42

LANDING_TP_INDUSTRIES_TREE_TITLE

  • Building materials
  • Cosmetics and perfumery
  • Chemical Industry
  • Metallurgical Products
  • Medical supplies
  • Other

LANDING_TP_INDUSTRIES_TREE_TITLE2

  • 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

LANDING_TP_INDUSTRIES_TREE_TITLE

  • Tires
  • Parts for vehicles
  • Vehicles

LANDING_TP_INDUSTRIES_TREE_TITLE2

  • 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

LANDING_TP_INDUSTRIES_TREE_TITLE

  • Banking services
  • Activities in the financial services and insurance

LANDING_TP_INDUSTRIES_TREE_TITLE2

  • Loans
  • Logistics
  • Lease
Food industry, agricultural products
4

Food industry, agricultural products

To industries
01 4

LANDING_TP_INDUSTRIES_TREE_TITLE2

  • Corn
  • Seed
  • Confectionery
Healthcare and Pharmaceuticals
2
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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
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