To our clients, GRATA offers the following legal services in the area of transfer price formation:

• Examination and providing legal opinions on new export-import contracts;
• Monitoring of transactions;
• Providing information on market prices and accompanying expenses related to the product delivery to world markets;
• Pre-review audit;
• Accompanying tax inspections;
• Appealing tax inspection results.

All given information is presented in systematized form (calculations and documents) and this would avoid inconveniences in searching for information and documents as well as submitting them to tax bodies.

Examination and providing legal opinions on new export-import contracts.

Preliminary analysis of contracts i.e. examination and detection of possibilities where transfer price formation can be applied, herewith the commentaries and recommendations regarding the application of such contracts, inter-calculations with purchasers, business correspondence, etc will be prepared.

Monitoring over transactions.

We offer permanent monitoring over transactions on transfer price formation i.e. providing transfer calculations with regards to each delivery or transaction whilst checking the correctness of price formation and completeness of confirmatory documents. The client will be furnished with a legal opinion on possible breaches and recommendations how to eliminate them upon results of monitoring.

Pre-review audit.

According to the last tax reviews, due to preparation of documents and arguments in advance, ungrounded taxes, fines and charges can be avoided. Taking into consideration the remaining importance of the problem, we suggest adopting preventative measures prior to a new tax review.

We are able to provide a pre-review audit of the periods uncovered by tax bodies, herewith calculation will be made, breaches will be avoided, client’s position will be enforced and the full pack of documents necessary for tax review will be prepared.

Obtaining information on market prices and appropriate documents related to expenses of product delivery to appropriate markets (differential).If the information included in your documents will be incomplete for calculations we would obtain it from other sources. As you know, tax bodies take official sources of information, adopted by the Government of the Republic of Kazakhstan, into consideration.

GRATA has established friendly relationships with many information service providers on market prices which would allow us to obtain information taking the specificity of your supply into account.

Accompanying tax review on transfer price formation.

Usually during tax reviews disputes may arise between clients and inspection bodies. Owing to this we are able to accompany tax reviews i.e. make calculations using methods and forms adopted by tax bodies as well as participate in discussions.

During discussions the algorithm of evidence will be built which will be based on calculations with confirmatory documents. When necessary, additional documents enforcing your arguments will be collected as well.

Appealing tax review results on transfer price formation.Mainly appeals on tax review results on transfer price formation are heard in superior tax bodies or in courts.

Due to this, GRATA is able to represent your interests in the given bodies by professionally preparing application for an appeal.

The application for an appeal will be accompanied by calculations which will be grounded on confirmed documents.

When necessary, additional documents enforcing your arguments will be collected. Our long standing positive experience in matters of transfer price formation would be a reliable defense of your interests in future tax disputes.