Controlled Operations Report
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Find out if your foreign payments are controlled operations!
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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
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
Manufacturing
8
Services
7
Finances
10
Comparison methods for transfer pricing
projects
45
Comparable Uncontrolled
Price Method (CUP)
projects
12
Transactional Net Margin Method (TNMM)
projects
32
Resale Price Method (RPM)
projects
11
Cost Plus Method (CPM)
projects
0
Profit Split Method (PSM)
Number of projects by industries
Equipment and machinery
10
Manufacturing
42
Automotive Industry and Special transport
4
Construction and Real Estate
2
Trading equipment
1
ІТ / Software /SaaS
1
Finance, Banking, Insurance and Fintech
12
Food industry, agricultural products
4
Healthcare and Pharmaceuticals
2
Get ready made Controlled Operations report in three days
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 operation2. 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 pricing2. 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 operationsх2. 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 information2. 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
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
Defining a market range of prices / profitability
1. Description of the approach to the application of the CUP method / net profit2. 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
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