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What were the results of the business breakfast entitled “Transfer Pricing”?

On 18 March 2010, TACOMA held a business breakfast for its clients entitled “Transfer Pricing”.

The event was presented by Radka Svobodová, Manager of TACOMA Valuation and Jaromír Zbroj, Senior Manager of TACOMA Tax who head up consultancy in the area of transfer pricing at the company. Another speaker was Jiří Teichmann, a tax advisor and one of the Czech Republic’s foremost transfer pricing experts, having been head of transfer pricing consultancy services for Ernst & Young for several years and now working on a subcontract basis for TACOMA in this area.

The occasion was attended by representatives of major domestic companies that encounter intragroup transfer pricing issues in their everyday practice. The workshop, therefore, covered a number of actual problems concerning intragroup transfer pricing.

Managerial services undoubtedly represent the most searching problems. The company representatives drew attention to problems with evidence that services had been provided in an amount corresponding with the agreed consideration. Another major problem they identified was rigid communication with parent companies, and, in this respect, the workshop provided several useful recommendations.

The workshop also drew attention to the fact that price mechanisms established in more prosperous times may not suit the present day, in which the profitability of groups of enterprises is changing. Modifying the set up, however, may be difficult and risky, as tax administrators may argue that if a company continues with the same activity and changes its pricing methodology, either the past or current set up must be wrong. Therefore, a detailed analysis of the situation and justification of changes is necessary in order to minimise the risk of transfer prices being disputed by the tax administrator.

In the Czech Republic, the transfer pricing issues are currently subject to increasing interest; not only from more and more companies, but mainly from tax authorities, who are focussing their reviews ever more often on this area. A company’s readiness to meet the review criteria plays a major role here.

TACOMA offers you comprehensive services in transfer pricing. The pooling of knowledge and experience within our team of tax consultants, who specialise in transfer pricing issues, and valuation experts, is the ideal solution when it comes to transfer pricing for any company.

If you are interested in more information, we are available at the contact details below.

Radka SVOBODOVÁ, Manager of TACOMA Valuation
Tel: +420 226 219 057
Mobile: +420 731 411 263
E-mail: radka.svobodova@tacoma.eu  
www.tacoma.eu