SERVICES

TRANSFER PRICING

We have expertise on a broad spectrum of different transfer pricing projects, among the following:

Financing activities (i.e. back-to-back financing activities, provision of loans to related parties, Debt Capacity analysis, financial Guarantees, etc)
Provision and receipt of services
International trading of goods
Local distributors of Multinational companies
Licensing and valuation of Intangibles
Determination of Embedded Intellectual Property Income, included in sale of goods and provision of services
Business restructurings
Assistance with preparation of Master files
Assistance with preparation and filing of country by country reports

We have also years of experience with complicated Tax advisory projects such as:

Complicated Tax and VAT advisory projects on cross border transactions and business restructurings
International Tax Structuring involving multiple jurisdictions
Advice and guidance in the light of the changing international and EU tax landscape (encompassing BEPS initiatives and EU anti-avoidance directives, etc)
Preparation and filing of tax rulings with the Cyprus Tax Department
Application and use of the Cyprus IP box Tax Regime
Assistance with Tax examinations/disputes with the Cyprus Tax Department
Tax and VAT due diligence reports