Transfer Pricing

The control over transfer price-formation is one of the state’s considerations. The control over transfer price formation is a special type of control that differs from simple tax inspection and requires special approach in controls over international business transactions.

The control by Tax bodies are conducted on the basis of comparison between market price and the deal price and in case there is a difference, the deal price becomes a transfer one i.e. the deal price was undervalued in export or overvalued in import.

Should such facts occur will Tax bodies adjust the income and impose taxes and payments. The adjustments of income are made with regards to the difference between factual (deal price * volume) and rated (market price * volume) income.

GRATA has got a successfully operating Department of Transfer Price Formation specializing only on matters of transfer price formation of our clients. The Department is being headed by Arman Mendybayev who was the head of the Department of Transfer Price Formation at the Tax Committee of the Ministry of Finance of the Republic of Kazakhstan. He was a leader of all major tax reviews, creator of all normative legal acts on transfer price formation i.e. founder of this area in tax bodies.

Our Products:

An analysis of the export and import contracts, in order to determine whether there are any risks associated with the transfer price

The conclusion of the agreement made with the Ministry of Finance, in relation to transfer pricing

Preparation of the monitoring transactions for transfer pricing to submit to the tax authorities

The previously verified audit

Tax audits on transfers: support and appeals