Transfer pricing refers to the terms and conditions applied to transactions between related parties, including the pricing of goods and services transfers. With extensive experience and a multidisciplinary team, our firm provides comprehensive transfer pricing reports – local documentation to ensure compliance with Serbian tax authority requirements and the arm’s length principle.

Our experts guarantee the highest quality final report, which is submitted with the annual tax return. The local report includes:

• Detailed information about transactions with related parties
• Functional analysis identifying, roles and responsibilities of the related parties
• Selection and application of appropriate methods for evaluating transfer prices
• Comparability analysis using relevant data and OECD guidelines
• Conclusion providing a clear picture of the compliance of your transactions with the arm’s length principle.

Our Transfer Pricing Report (local documentation) ensures a precise and comprehensive analysis of your related party transactions, providing you with security and peace of mind in a tax environment.

Contact us today to ensure your transfer pricing is compliant with tax requirements and OECD guidelines

BEPS Action 13 introduced a new report called the Master File, mandatory in jurisdictions that have adopted this regulation. The Master File collects standardized information at the business group level to enable tax authorities to assess transfer pricing risks.

Our firm provides support in aligning the information needed in the Master File, which includes five categories of relevant data:

1. Information about the Master File
2. Organizational structure of the multinational group
3. Intangible investments within the multinational group
4. Financial and tax position of entities within the multinational group
5. Financial activities within the multinational group.

Our expert team will support you in preparing a quality Master File, ensuring that all relevant information is correctly grouped and aligned with OECD transfer pricing guidelines. This way, you can meet tax requirements and ensure transparency in the global economic, legal, financial, and fiscal context of your multinational group.

Contact us today for expert support in preparing your BEPS Action 13 Master File

OECD transfer pricing guidelines through BEPS Action 13 mandate the Country-by-Country Report (CbCR), which requires a set of tax data at the level of each tax jurisdiction. This report provides information on the global allocation of income and taxes paid, as well as indicators of the location of economic activities in the tax jurisdictions where the multinational group operates.

Our firm provides support in preparing the Country-by-Country Report (CbCR), which is crucial for global transfer pricing risk assessment. By providing all relevant financial data of the multinational group by tax jurisdiction, such as revenue, profit, pre-tax profit, registered capital, etc., and a description of the main economic activities of each member entity, we ensure that the CbCR is accurate and comprehensive.

With our expert support in preparing the CbCR, you can be confident in meeting tax requirements and ensuring transparency regarding the allocation of income and taxes paid worldwide. Our team of experts will provide a comprehensive analysis and support in preparing the Country-by-Country Report that will be beneficial for global transfer pricing risk assessment.

Contact us today to help you prepare your Country-by-Country Report for transfer pricing

Value chain analysis is a comprehensive service where we identify and evaluate each stage of a company’s business chain, from sourcing raw materials to delivering the final product. This process involves mapping out core activities, assessing the allocation of resources, and analyzing costs, margins, and profitability across the entire chain. We help companies pinpoint inefficiencies, assess the value contribution of each step, and make data-driven recommendations to optimize performance. Ultimately, this approach enhances operational efficiency, reduces costs, and ensures that companies maximize value while remaining competitive in the global marketplace.

Contact us today to help you prepare your Value Chain Analysis Report

Determining the value of a business is crucial and involves assessing the resources it can develop and generate. To evaluate the value, it is necessary to analyze different scenarios to determine the likelihood and consequences of each. The first step is to identify the most appropriate valuation method, which will depend on the company’s characteristics, cash flow generation capabilities, and available information. For active companies with stable cash flows, the discounted cash flow (DCF) method is commonly used. The multiplier method, based on financial and functional information of comparable independent companies, is also often applied. Indicators such as sales, EBIT, EBITDA, market capitalization, etc., are used in this methodology.

Our valuation service for businesses, shares, and intangible assets includes the following steps:

1. Analysis of the company being evaluated
2. Selection of the most appropriate valuation method or methods
3. Development of a valuation model that considers the company’s specifics
4. Application of the valuation model based on relevant data and information
5. Defining the range of estimated value, considering various factors and scenarios.

Our expert team will provide you with professional opinions and support throughout the valuation process, giving you a clear picture of your company’s value.
Additionally, we have long been experts in valuing intangible assets. As industry leaders, we provide high-quality valuation services for intangible assets to help our clients make informed business decisions.

Our approach to valuing intangible assets is comprehensive and thorough. We use the latest methods and techniques, considering all relevant factors and parameters affecting value. Our goal is to provide clear and transparent results, giving you all the information needed for decisions regarding your intangible assets.

We handle the valuation of various types of intangible assets, including intellectual property, brands, patents, copyrights, software, licenses, and other intellectual resources.

Contact us for reliable valuation of capital or intangible assets and we will gladly provide all the information you need

Our strategic transfer pricing planning service offers advice and support in planning transactions with related parties and/or tax havens. The goal of this analysis is to define transfer prices optimally adapted to decentralized structures, to achieve organizational efficiency, optimize the valuation of these operations, and ensure compliance with the arm’s length principle, reducing the risk of unforeseen situations with the Tax Administration. Our purpose is to maximize your company’s results through the application of the most appropriate transfer pricing methodology.

Our approach includes the following steps:
a. Business analysis and identification of potential transfer pricing challenges
b. Defining transfer prices that align with your organizational structure and goals, considering legal requirements and international guidelines
c. Development and implementation of transfer pricing policies, including clear instructions for application and active involvement of all relevant stakeholders
d. Integration of the transfer pricing plan into the organizational environment to ensure consistency and efficiency in application.

Our expert team will support you throughout the process, helping you implement transfer pricing policies and integrate them into your organizational environment. Our goal is to ensure your business achieves maximum results with optimal transfer pricing application.

Contact us today to help with strategic transfer pricing planning and optimize your business

In the event of a Tax Administration inspection, we offer expert support and assistance in identifying optimal and efficient alternatives. As the only registered court expert for transfer pricing in Serbia, we have extensive experience supporting our clients during inspection processes, focusing on achieving satisfactory dispute resolution in collaboration with relevant authorities.

Our service includes:

1. Situation analysis: We carefully analyze documentation and information relevant to the Tax Administration inspection to understand the situation and identify potential challenges
2. Consulting and strategy: Based on our extensive transfer pricing experience, we provide expert advice and suggest an optimal strategy to help resolve the dispute
3. Preparation of responses and documentation: We assist in preparing detailed responses to Tax Administration requests and documentation needed to support your case
4. Monitoring and negotiations: We monitor the inspection progress and, if necessary, actively negotiate with the Tax Administration to achieve a satisfactory dispute resolution in your favor
5. Court expertise: If the situation escalates to court, as a registered court expert for transfer pricing, we provide expert opinions and reports that can be crucial for dispute resolution.

Our goal is to provide support and help you overcome the challenges of a Tax Administration inspection, ensuring satisfactory resolution. Contact us today to help you effectively and successfully resolve your case.