Transfer pricing considerations that taxpayers should keep in mind when completing year-end tasks.
The deadline for income tax compliance is approaching and taxpayers have to consider reviewing their transfer pricing position. You may need to evaluate whether to adjust related-party payments or transactions, amend existing transfer pricing policy or agreements, or establish transfer pricing policies for new transactions or lines of business.
In light of income tax compliance, we have prepared a set of transfer pricing considerations that taxpayers should keep in mind to meet the requirements of the Law “On Income Tax”.
Identify all relevant transactions
Confirm financial results are consistent with transfer pricing policies
It is also important to determine whether the relevant documentation (e.g., benchmarking analyses, external comparables, etc.) supports the arm's length price used. In addition, it may be prudent to revisit a transfer pricing policy and related supporting documentation to support arm's length pricing if the following have changed:
KPMG expertise is available
To help identify any gaps that may exist and to assist in mitigating adverse transfer pricing findings in the event of an audit, consult a trusted transfer pricing professional, especially before:
Our transfer pricing experts are ready to answer your questions and provide you with the benefit of our worldwide network of transfer pricing practitioners.
For more information, contact KPMG.
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