Transfer pricing study
Functional analysis, selection of the most appropriate method, and search for comparables to demonstrate that your transactions meet the arm's-length principle.
Tax · Transfer Pricing
Transfer Pricing
If you transact with related parties, the DIAN already knows it. The question is whether your documentation holds up.
Transfer Pricing
Related-party transactions: the front that has grown fastest in tax audits
Any company that transacts with related parties abroad — or with residents of low-tax jurisdictions — is required to prove that those transactions were priced as independent third parties would have agreed.
This isn't a formality: it's one of the fronts where the tax authority has intensified its scrutiny the most, and where weak documentation translates into costly adjustments and penalties.
This capability joins our portfolio through the strategic alliance with CLA Brasil, with the methodology and access to comparable databases the OECD standard requires.
Talk to a specialistWhat we do for you
Supporting documentation
Preparation of the local report (Local File) with the content and structure Colombian regulations require.
Informative return
Preparation and filing of the transfer pricing informative return within the legal deadlines.
Master File
When your multinational group is required to, we prepare the master file describing the group's global operations.
Planning of related-party transactions
Structuring the transaction before executing it is infinitely more efficient than justifying it afterward. We support you through that design.
Defense during tax audits
When the DIAN questions your transfer pricing, the quality of the study and its support is the only thing protecting you. We support you through the discussion.
PGA · CLA Brasil strategic alliance
Capabilities expanded by the alliance
This service is provided with the direct backing of the international network:
OECD methodology
Application of the international transfer pricing standard, recognized by tax authorities.
Comparable databases
Access to the information databases that support the arm's-length analysis.
Cross-jurisdiction coordination
When the transaction involves Brazil or another market in the network, we work with the local team on the other side.
Let's talk about your company
Tell us about your specific situation. A partner or senior supervisor — not a rotating team — will review your case and propose the scope you actually need.
Talk to a specialist