Transfer pricing services

Cross-border business transactions with related associated parties have to be established in accordance with the internationally accepted arm’s-length-principle and must be documented in line with domestic tax rules. 

Your business model constitutes the starting point of any transfer price setting. Our transfer pricing specialists' objective is to serve you in the implementation of your business goals.

Based on our long-term experience in transfer pricing, both within Lithuania and abroad, we may support you in the design of efficient transfer pricing structures as well as in the reduction of tax-related risks.

Our highly-skilled experts in Lithuania and worldwide is a benefit for your business. Nearly 100 Rödl & Partner transfer pricing professionals in more than 32 countries may serve you in a wide range of transfer pricing issues.

Transfer Pricing services by Rödl & Partner Lithuania:

A team of highly-skilled transfer pricing professionals at Rödl & Partner Lithuania advises and supports the clients with its' industry expertise in the development of a transfer pricing strategy tailored to clients' business. 

Our services include the entire spectrum of transfer pricing services, in particular:

1. PLanning, creation and implementation:

• Analysis of the existing transfer pricing systems under risk considerations
• Development of a transfer pricing system concept and choosing a method
• Implementation of transfer pricing systems in tax and legal terms
• Establishment of group-wide transfer pricing guidelines
• Consideration of related tax issues (e.g. questions about staff posting, permanent establishments or, customs etc.)
• Support in national special topics (e.g. business restructurings, national regulations against BEPS).

2. Documentation and country-by-country reporting:

• National coordination and preparation of transfer pricing documentation (e.g. Master file, Local file)
• International documentation concepts (e.g. OECD Masterfile Concept)
• Preparation of benchmark studies and database analyses
• Annual financial updates of benchmark studies and database analyses
• Preparation, conversion and analysis of Country-by-Country Reports.

3. Audit and dispute resolution:

• Identification of transfer pricing risks (”stress tests”)
• Support during domestic and foreign tax audits
• Advice on issues related to appeal proceedings
• Support during arbitration proceedings
• Support during mutual agreement procedures
• Consulting in APA (Advanced Pricing Agreements).

4. Special topics:

• Transfer of functions
• Permanent establishments
• Cost allocation systems
• Financing
• Valuation of intangible assets
• Determination of license fees
• Determination of interest rates
• Transfer pricing-due diligence
• Structure of an operative transfer pricing management.