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General

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

2.Do intercompany transactions take place within the group?

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

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

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

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

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

Transfer pricing documentation

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

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

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

10.Is a master file prepared?

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

Specific questions

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

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

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

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

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?

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?

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

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

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

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?

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?

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

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

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

Does your Group carry out triangular transactions?

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

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?

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?

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

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

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

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?

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

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

If YES, please specify:

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

If YES, please specify:

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

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)?

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

4. Contact details

Name:

Title and Position:

Email:

Tel.: