We emphasize that the support of auditors even before the preparation and submission of the Report on controlled transactions will allow to correctly identify the entire scope of controlled transactions, to determine the appropriate method of justifying compliance with the “Arm’s length” principle of pricing, which in turn can prevent the application of penalties (financial sanctions) provided for by the Tax Code of Ukraine.
Quite often, a taxpayer needs to clearly understand all the risks of its controlled transactions at the stage of their implementation in order to be able to create an effective and reliable basis for further ensuring the proper justification of its pricing (for example, the presence of internal comparable transactions or monitoring of external prices) and to minimize tax risks when dealing with fiscal authorities.
We have experience not only in working with primary documents created by the payer, but also with various analytical information bases, which are recognized by regulatory authorities as independent information sources. They include Ruslana, Amadeus (owned by the information office VanDejk), Cbonds, Eikon, etc. We conduct analytical work on obtaining and processing the information accumulated in the stock and commodity markets and collect a large array of data from other publicly available sources of information, which is further systematized, analysed and applied for the purpose of justifying pricing in controlled transactions of the Client.
Our team has gained quite an extensive experience in justifying various types of controlled transactions and we can say for sure that it is impossible to find exactly the same taxpayers, just like it is impossible to fit different controlled transactions in one typical template of documentation. Each set of documents prepared by us is a thorough study combining at least two methods of justification, which in turn makes it possible to use the maximum number of arguments in favour of the taxpayer.
This is the final, but no less important stage of cooperation with the Client, who as a result of cooperation with us gets confidence that in case of inspection by a regulatory authority, its interests will be protected, the position proved, and financial resources saved.
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