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Intragroup transactions

Intragroup transactions

Intragroup transactions. Financial and service costs. Transfer pricing analysis and risk assessment. Advance pricing agreements. Exit tax

Intragroup services. Financing costs. Deductibility limits. Exit tax

Therefore, the International Corporate Tax Team offers the following services to its Clients:

  • reviews of intragroup transactions with regard to the statutory limitations of tax deductible costs (services, financial costs);
  • analysis of intragroup transactions in order to assess the risk of applying anti-avoidance provisions (e.g. GAAR, planned exit tax) and to mitigate these risks (verification or assistance in preparation of defence files);
  • application for tax rulings covering purchase transactions with related entities (services, royalties, financial costs);
  • support of taxpayers in proceedings regarding the advance pricing agreements;
  • analysis of intragroup transactions and cash flows in terms of compliance with reporting obligations (e.g. withholding tax);
  • preparing the statutory transfer pricing documentation.

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