Transfer Pricing

Transactions with related parties registered outside the country are under special control of the tax authority due to the high risks associated with violating market principles.

Loialté’s Transfer Pricing services ensure transparency, compliance with regulatory requirements, and effective management of the associated risks of your company’s controlled international operations.

Our team will review your controlled transactions and assess their compliance with market principles. As a result, you will receive a reasoned conclusion that will help you develop effective transfer pricing policies and documentation, as well as manage tax risks and properly manage relations with the tax authority.

What does transfer pricing service include?

Transfer pricing requires in-depth analysis and a proper understanding of tax legislation: 

  • Detailed study and identification of transactions  – in the first stage, we analyze all operations carried out with related parties – be it the provision of goods or services, loan relationships or other types of transactions. We determine the economic content, purpose and possible tax impact of each transaction.
  • Market conditions analysis and pricing compliance  – In the next stage, we check whether the prices used by your company are in line with market principles. To do this, we use both local and international market data, including OECD guidelines and comparative analysis methodology.
  • Data collection, processing and comparative market research  – we collect the necessary financial and commercial data needed to determine the market price. At the same time, we assess the structure of each transaction and determine whether there is a tax risk associated with incorrect pricing.
  • Verification and optimization of the pricing methodology  – our experts assess whether the transfer pricing method is correctly selected and applied. If necessary, we offer an alternative method to reduce tax risks. 
  • Tax compliance assessment and risk identification  – we verify whether your operations comply with the requirements of Georgian tax legislation and international standards. At the same time, we assess possible tax risks and create an action map to avoid them.
  • Preparation of conclusions and recommendations  – based on the results of the analysis, we prepare a detailed report – a substantiated conclusion and recommendations that you can use both during a tax audit and in the decision-making process. The conclusion includes a reasoned position, data analysis, methodology used, and a description of further steps.

Representation with the tax authorities and ongoing support  – if necessary, the Loialté team will represent your interests in the process of communicating with the revenue service – when submitting documentation, issuing explanations or participating in discussions. This ensures your legal protection and comfort when dealing with the tax authorities.

Transfer pricing involves determining prices for transactions between related companies (e.g., the supply of goods, the provision of services, loans, etc.). Its goal is to ensure that transactions are carried out under market conditions, which eliminates tax manipulations based on artificially low or high prices.

The risk arises when transactions are carried out between related companies in different countries and the prices do not reflect the actual market value. In such cases, the tax authority may assess the transaction itself and impose additional payment obligations on you.

Yes, if you have relationships with related parties registered outside the country. In such cases, Georgian tax legislation requires you to keep transfer pricing documentation and submit it to the Revenue Service upon request.

When using the advance ruling request support service at Loialté, you will be met by experienced tax auditors and consultants with many years of experience working in both the private and public sectors (including the Revenue Service).

With our involvement, the legal assessment of transfer pricing issues is more secure and efficient, and our professional liability is insured by a leading insurance company. As a result, you insure your tax risks and receive a strategic partnership based on experience, legal accuracy and reliability.

Loialté holds the ISO 9001:2015 certificate in the field of tax services, which confirms the high quality of our services and compliance with international standards.

Loialté is the largest provider of the “Produce in Georgia” agency’s so-called Growth Hubs project, which means that entrepreneurs who meet the criteria set by the program can benefit from up to GEL 10,000 in co-financing in the following areas:

  • Finance and accounting
  • Taxes
  • Legal services
  • Business plan, strategic planning and business modeling
  • HR services

Additional information about the program can be found at the link.

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