Transfer pricing

We advise companies and organizations on various unique, complex, and strategic transfer pricing issues, for example, when planning the pricing for a new or atypical transaction, or assessing profit attribution to a permanent establishment, etc.

In advising our clients, we leverage years of experience and the best analytical tools available on the market, such as Moody’s TP Catalyst, RoyaltyRange, Ober-Haus, and others. Sometimes the most obvious answer is not the most correct or pragmatic, therefore, our goal is to help find a balance between practical solutions and controlling risk.

We perform thorough assessments of tax risks associated with past or planned future transactions between associated parties.

We analyse both existing pricing documentation and theoretical business plans for future expansion or reorganizations. Following the analysis, we provide recommendations for practical pricing solutions and the most appropriate documentation strategy.

This service is particularly beneficial for companies that engage in numerous large-scale and diverse transactions with foreign associated parties, wish to verify the compliance of their existing pricing documents, or simply seek more clarity while creating a pricing documentation strategy.

We prepare applications for Advance Pricing Agreements with the tax authorities for complex controlled transactions between associated parties. This procedure is designed to provide maximum certainty that the chosen transfer pricing policy aligns not only with legal interpretations but also with the actual position of the tax inspectorate.

APAs require a detailed evaluation by the tax authorities, which involves a significant time commitment for communication and the submission of documents and information. Consequently, this procedure is most recommended for highly atypical, large-scale, and high-risk transactions with associated persons in foreign jurisdictions.

We prepare Transfer pricing documentations for past transactions with associated parties in accordance to the local Lithuanian legislation, international OECD‘s Transfer pricing guidelines and the best international practice.

Our services include preparation of the Master File, which must be prepared by international enterprises with turnovers above 15 mil. EUR (in cases where this file is not prepared by another group company) as well as the Local File. We cooperate with Grant Thornton network advisors all over the world and can help prepare Transfer pricing documents in whichever country our client‘s company group operates in.

We take in to account the needs of our clients and offer pragmatic solutions in ensuring efficient Transfer pricing documentation compliance. In cases where formally the Transfer pricing documentation is mandatory but the transactions themselves carry very little or no tax risk at all, we often recommend choosing a more cost-effective and less time consuming compliance procedure – the preparation of a simplified Transfer pricing documentation. Such a document includes only the analysis of core transaction aspects and the evaluation of the transaction‘s compliance to the arm‘s length principle. During a tax audit, the tax administrator may demand a full Transfer pricing documentation and in such a case the taxpayer is given a 30 day period to provide it. If the taxpayer already has a simplified version of the documentation in which the transactions are found to be carried out at arm’s length, a period of 30 days is more than enough time to fill in the additional information.

We prepare Transfer pricing strategies and policies for future transactions in accordance to the local Lithuanian legislation, international OECD‘s Transfer pricing guidelines and the best international practice.

We help our clients choose a Transfer pricing method that is the most reliable and most appropriate to the specific situation at hand. By cooperating with Grant Thornton network companies all over the world, we help ensure that the pricing policy will be compliant to the local legislative requirements of every country in which it will be adopted. We provide advice on possible risks, practical application of pricing principles, help prepare calculation tables as well as provide Transfer pricing adjustment accounting note templates.

Considering the needs of our clients, we can produce tailored and exceptionally detailed Transfer pricing policies as well as simplified ones that are more appropriate for typical or lower-value transactions. The simplified Transfer pricing policies include only the core transaction aspects and Transfer pricing analysis ensuring the pricing arrangement’s compliance to the arm‘s length principle.

We prepare Transfer pricing benchmarking studies in determining market profitability, mark-up and margin rates for every industry. To get the most reliable results in the shortest amount of time, we utilise only the most modern databases and search tools („Moody‘s“ TP Catalyst Pro, etc.).

By cooperating with the best experts in their respective fields (RoyaltyRange, Ober-Haus etc.), we prepare market price benchmarks for sale/ rent of real estate, financing arrangements (loans), licencing deals and various other transactions.