Transfer Pricing and Related-Party Transactions

Transfer pricing and transactions between related parties

Documents

• Agreement on Withdrawal of a Related Party from a Cost Contribution Arrangement with a Buy-Out Payment
• Agreement on the Allocation of Synergy Benefits within a Multinational Group
• Justification of the Selected Transfer Pricing Method by Transaction Type
• Central Procurement Services Agreement for Members of a Multinational Group (Central Procurement)
• Share Sale Agreement in a Subsidiary between Related Parties with Fair Market Value Assessment
• Statement on Compliance of Related-Party Transactions with the Arm's Length Principle for Corporate Income Tax Return Purposes
• Cost Allocation Key Template for Services Rendered to Group Members
• Intragroup Mutual Claims and Obligations Netting Agreement
• Register of Intercompany Agreements for Transfer Pricing Documentation Purposes
• Arm's Length Compensation Adjustment Clause in Intercompany Agreements
• Record of Transactions with Persons from Jurisdictions with Preferential Tax Systems
• Form for Determining Related Party Status (Ownership and Management Connections)
• Contract on Sale of Goods between Related Parties with Price Determined by the Cost Plus Method
• Intra-Group Salary Cost Recharge Agreement for Seconded Personnel
• Business Restructuring Agreement within a Group with Transfer Pricing Exit Charge
• Agreement on the Sale of Fixed Assets between Related Parties with Market Value Assessment
• Decision on Determining the Arm's Length Interest Rate for Loans Between Related Parties
• Form for Calculation of Disallowed Interest Expenses under Thin Capitalization Rules
• Annex to the Intercompany Agreement on Annual Compensating Adjustment of Transfer Prices (True-Up)
• Request for Corresponding Adjustment of the Tax Base on the Grounds of Transfer Pricing Correction in a Foreign Country
• Contract Research and Development Agreement Between Related Parties (Contract R&D)
• Parent Company Guarantee Agreement for Subsidiary's Obligations with Arm's Length Compensation
• Agreement on Centralized Cash Management within a Group (Cash Pooling)
• Agreement on Low Value-Adding Services within a Multinational Group
• Contract on Processing of Materials Owned by the Ordering Party Between Related Parties (Toll Manufacturing)
• Limited Risk Distribution Agreement Between Related Parties (Limited Risk Distributor)
• Contract Manufacturing Agreement between Related Parties (Contract Manufacturing)
• Comparability Analysis Form (Benchmark Study) for Related Party Transactions
• Request for Conclusion of a Bilateral Advance Pricing Agreement on Transfer Pricing with Competent Authorities of Two States
• Functional Analysis Form (Functions, Assets, Risks) for Transfer Pricing Documentation
• Request for Conclusion of a Unilateral Advance Pricing Agreement (APA) on Transfer Pricing
• Transfer Pricing Documentation Local File Form
• Notification to the Tax Administration on the Ultimate Parent Entity and the Reporting Entity for Country-by-Country Reporting
• Master File Documentation Form on Transfer Pricing for a Multinational Group (Master File)