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As of 01.01.2016, there is a change regarding the moment of the call of FR SR to submit the documentation for transfer pricing for a relevant taxable period. This call may be sent only on the first day following the deadline for submitting the tax return for a relevant taxable period.

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Our company has access to the database Amadeus, through which we are able to fully assist clients in managing transfer pricing documentation. A member of our tax team is a specialist on the issue of transfer pricing, hence we are able to provide advice of high quality.

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Transfer Pricing Update

Has your business been affected by the COVID-19 pandemic? It may also have an impact on your transfer pricing. Companies have been experiencing fluctuations in revenues and cash flows and facing forced closures during the pandemic. On the other hand, certain segments and companies have strengthened their position significantly. Many countries have intervened and provided…


The continued economic impact of COVD-19 across the globe has naturally forced or accelerated the process of businesses to review their existing operations and commercial arrangements. Companies have taken stock on the impact of COVID-19 on their financials, business models and supply chains. For multi-national enterprises (MNE’s), their transfer pricing policies are a critical part…

Production models

Manufacturing activities in a group can be organized in different forms. In general, we distinguish four basic models, namely: a full-fledged producer, a manufacturer with limited powers, a contracted manufacturer, and wage labor. A full-fledged manufacturer carries out all manufacturing activities, from the design of the product to the final sale to the customer. This…

New edition of the OECD Transfer Pricing Guidelines

On 10 July 2017, the OECD released a new revised edition of its Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The introduced changes are significant globally since the OECD Guidelines represent the major and most reputable regulation resource on transfer pricing. The new edition especially includes the changes that were approved during 2015…