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First Step
First Step and Pricing
Engagement Step

General

1.Does the group include foreign entities and/or permanent establishments/branches?

Yes No

2.Do intercompany transactions take place within the group?

Yes No

If yes, please further specify the type of intercompany transactions.

3.Have intercompany agreements been concluded for the intercompany transactions?

Yes No

4.Are transfer pricing policies (i.e. overview how to remunerate a transaction, such as cost plus x%) set-up for these intercompany transactions?

Yes No

5.Are benchmark studies performed to substantiate the remuneration for the intercompany transactions?

Yes No

6.Do these benchmark study(ies) contain data for the year 2016 and/or later years?

Yes No

Transfer pricing documentation

7.Has the group a consolidated revenue exceeding EUR 750 million?

Yes No

8.Has the group a consolidated revenue exceeding EUR 50 million?

Yes No

9.Is a country-by-country report prepared?

Yes No

10.Is a master file prepared?

Yes No

11.Are local files prepared for the entities and/or permanent establishment/branches engaged in intercompany transactions?

Yes No

Specific questions

12.Do intercompany transactions occur with entities and/or permanent establishments/branches located in low tax jurisdictions (tax havens)?

Yes No

13.Do intercompany transactions occur that constantly result in losses on one or both sides of the transaction?

Yes No

14.Have business restructurings taken place within the group (e.g. shift of the location of production)?

Yes No

15.Has there been any transfer of intangible assets within the group (e.g. transfer of a client portfolio)?

Yes No

General information

1.How many companies belong to your Group?

2. Please complete the activity code/s (NACE Code/s) of your company.

3. Are the Financial Statements of your company audited by a certified accountant?

Yes No

4. If your entity is a permanent establishment in Cyprus, please complete the jurisdiction of the headquarters.

5a. Is the Ultimate Parent company (UPC) of the Group registered in a jurisiction that applies Transfer Pricing (TP) regulations?

Yes No

5b. Does the UPC or other associated company prepare a TP Master File in accordance with OECD Guidelines?

Yes No

6. Has the Group conducted an Advance Pricing Arrangement (APA) with a Tax Administration?

Yes No

7. Has your company ever prepared a TP local file in accordance with OECD Guidelines?

Yes No

Description of intragroup transactions that fall under the TP rules

1. For how many categories of transactions your company is above the threshold of 750k?

2. Your intragroup transactions refer to:

1. Basic Information for the interested entity (A)

Company Name:

VAT or Registration number:

Country of Residence:

Net sales or turnover (in million EUR):

Short business description and activity Code (NACE Rev 2):

Period under evaluation: From

Until:

2. Basic Information for the related parties

Company Name:

VAT or Registration number:

Country of Incorporation or Residence:

Activity Code (NACE Rev 2):

Net sales or turnover (in million EUR):

3. Short description of intragroup transactions

3a. Intragroup sales/purchases of goods (If there are no intragroup transactions on goods, please ignore this section)

Please describe the goods sold to / purchased by related entities:

Intragroup sales of goods (amount in million EUR):

Are the same goods sold to independent clients?

Yes No

If YES, please specify the ratio Intragroup sales / total sales (%):

Intragroup purchases of goods (amount in million EUR):

Are the same goods purchased by independent suppliers?

Yes No

If YES, please specify the ratio Intragroup purchases / total purchases of goods (%):

Are the intragroup sales/purchases of goods governed by private agreements?

Yes No

If YES, are there similar private agreements with independent clients?

Yes No

Does your Group carry out triangular transactions?

Yes No

3b. Intragroup provision/receiving of services (If there are no intragroup service transactions, please ignore this section)

Yes No

Please describe the services provided to / recieved by related entities:

Intragroup provision of services (amount in million EUR):

Are the same services provided to independent clients?

Yes No

If YES, please specify the ratio Intragroup sales / total sales (%):

Intragroup purchases of services (amount in million EUR):

Are the same services purchased by independent vendors?

Yes No

If YES, please specify the ratio Intragroup purchases / total purchases of services (%):

Are the intragroup provision/purchase of services governed by private agreements?

Yes No

If YES, are there similar private agreements with independent clients?

Yes No

3c. Other intragroup tramsactions (If there are no other intragroup transactions, please ignore this section)

Did your company enter into a loan agreement with related parties?

Yes No

If YES, has your company granted/received loans to/from other independent entities (banks, etc)?

Yes No

Did your Company transfer/purchase tangible assets to/from a related entity?

Yes No

If YES, please specify:

Did your Company transfer/acquire intangible assets (such as trademarks, patents, know-how etc) to/from a related entity?

Yes No

If YES, please specify:

Has the Group conducted an Advance Pricing Arrangement (APA) with a Tax Administration?

Yes No

If YES, please specify the competent Tax Authority and the set of criteria (method, comparables etc) for the said transactions.

Are there transactions covered by a Cost Contribution Arrangement (CCA)?

Yes No

If YES, please specify the scope and the participants of the CCA.

4. Contact details

Name:

Title and Position:

Email:

Tel.:

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