Trans­fer pric­ing con­sul­tancy ser­vices to top de­mand in SEE re­gion

Top 100 See - - Top 100 Banks -

Which of the coun­tries that you cover in South­east Europe (SEE) have ad­vanced the most in terms of tax leg­is­la­tion and which ones are lag­ging be­hind, and why?

The EU mem­ber states in the re­gion have pro­gressed in mod­ernising their tax leg­is­la­tion, and so have some non-EU coun­tries that are im­ple­ment­ing some ba­sic EU di­rec­tives with the aim to com­ply with the Euro­pean leg­is­la­tion. In this re­spect, coun­tries like Cyprus, Bulgaria, Greece, Ro­ma­nia, and Croa­tia have an ad­van­tage and that is why they are a tar­get for for­eign in­vestors. Ser­bia and Mon­tene­gro are also busi­ness-friendly coun­tries, while Al­ba­nia is mak­ing tremen­dous progress com­pared to the past in this re­spect.

How is Euro­fast po­si­tioned to com­pete with other ma­jor com­pa­nies pro­vid­ing the same ser­vices in the re­gion?

Euro­fast is a re­gional busi­ness ad­vi­sory or­gan­i­sa­tion em­ploy­ing over 200 peo­ple in SEE and the East Mediter­ranean through fully fledged sub­sidiaries in Le­fkosia, Athens, Thes­sa­loniki, Sofia, Bucharest, Bel­grade, Pod­gor­ica, Ti­rana, Skopje, Za­greb, Pristina, Banja Luka, Sara­jevo, Cairo, Alexan­dria, Tbil­isi, Kiev, Moscow, North­ern Iraq, Le­banon and Bei­jing.

Our ex­ten­sive port­fo­lio of ser­vice lines gives us the ad­van­tage to act as a “one stop shop” for in­ter­na­tional com­pa­nies. Euro­fast works se­lec­tively with in­de­pen­dently owned as­so­ciate com­pa­nies to of­fer clients com­pre­hen­sive and well-rounded so­lu­tions for any ad­di­tional ser­vice they re­quire.

What is the out­look for trans­fer pric­ing ser­vices in SEE?

Good ques­tion! Due to the tax Base Ero­sion and Profit Shift­ing (BEPS) ini­tia­tive of the Or­gan­i­sa­tion for Eco­nomic Co­op­er­a­tion and Devel­op­ment (OECD), we will have changes to do­mes­tic trans­fer pric­ing law and reg­u­la­tion through­out the globe, and it is an­tic­i­pated that trans­fer pric­ing ser­vices will again be on top of de­mand in SEE. Let's not for­get that in most coun­tries across the re­gion, trans­fer pric­ing is a new devel­op­ment. New reg­u­la­tions will in­crease com­plex­ity and will lead to the need for ex­tra ser­vices.

Are there any risk in­di­ca­tors for the Bul­gar­ian tax au­thor­i­ties? Are there any dif­fer­ences with other tax au­thor­i­ties in SEE?

High trans­fer pric­ing risk ar­eas are usu­ally sim­i­lar from coun­try to coun­try across the re­gion mainly be­cause the mo­ti­va­tion re­mains the same - “how an en­tity can min­i­mize its tax li­a­bil­ity”. How­ever, in Bulgaria due to low tax rate of 10%, the mo­ti­va­tion is not in­tense. Nev­er­the­less, de­mand on pub­lic ser­vices con­tin­ues to grow in the re­gion as more and more coun­tries strengthen ef­forts to elim­i­nate such cases. In­di­ca­tors of high risk ar­eas usu­ally can be found in trans­ac­tions with tax heav­ens, trans­ac­tions with com­pa­nies that have tax losses for uti­liza­tion in a multi­na­tional or­ga­ni­za­tion and ma­te­rial ser­vice trans­ac­tions with­out sub­stance.

How do you help com­pa­nies man­age their trans­fer pric­ing is­sues and what ser­vices do you pro­vide?

In light of the changes in the in­ter­na­tional tax land­scape and due to the rea­son that one of the key chal­lenges in in­ter­na­tional tax­a­tion is trans­fer pric­ing, tax­pay­ers should man­age their trans­fer pric­ing risks by be­ing aware of key risks. Our so­lu­tions in­clude prepa­ra­tion of the trans­fer pric­ing doc­u­men­ta­tion, trans­fer pric­ing model de­sign, re­view and lo­cal­iza­tion of the group mas­ter file and com­pli­ance with each coun­try's law.

Panayi­o­tis Dial­li­nas, Di­rec­tor Re­gional Op­er­a­tions, in­volved in the devel­op­ment of the Group’s busi­ness in the wide Balkan Re­gion

Anas­ta­sia Sa­gianni,

head of the Euro­fast Trans­fer Pric­ing divi­sion,

now lead­ing Euro­fast TP team in SEE

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