Small and medium-sized enterprises (SMEs) play an important role in the EU economy (and beyond). The more SMEs participate in cross-border activities, the more they are confronted with obstacles due to different tax systems which generate excessive and disproportionate compliance costs. One of the biggest international (direct) taxation challenges is probably transfer pricing (TP).

TP means setting the price for transactions between associated enterprises which is legally required to happen at an arm’s length, i.e. like between unconnected parties. In most countries exemption rules exist for SMEs under certain circumstances, depending criteria such as headcount and/or turnover / balance sheet limits.

The protection of SMEs by exemptions tends to be eroded with businesses growing and taxation rules changing. ETL GLOBAL’s transfer pricing teams are prepared to support their clients in all challenges coming up. Some countries / firms to be mentioned here in particular:

Czech Republic: As reported in April, ETL GLOBAL has joined forces with V4 Account of V4 Group. V4 Group inter alia focusses on TP consultation, including TP assessment, documentation, review, implementation in accounting systems and preparation of internal directives.

Germany and the Netherlands: Specialised colleagues, for example at PNHR, ETL Heuvelmann & van Eyckels and ABC Accountants are prepared to support SMEs in the TP matters.

Poland: About one and a half years ago, SWGK became member of ETL GLOBAL (see newsletter of March 23, 2021). SWGK is focusing inter alia on TP and has developed its own Transfer Pricing Manager software.

Spain: There are various colleagues within ETL GLOBAL Spain focussing on TP consulting, inter alia at the offices of ANTEO, AUDICONTULTORES, ETL GLOBAL ADDIENS and EJASO.

UK: Various offices of ETL GLOBAL UK offer international tax services including TP – for example MGR Weston Kay, Gerald Edelman or Wilder Coe.

China, Vietnam and APAC region: The Dezan Shira TP Team offers comprehensive TP services all over Asia, in particular but not limited to the review of related party agreements, the performance of benchmarking studies and TP documentation.

Feel free to contact the above listed teams directly or centrally through ETL GLOBAL.

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