Transfer Pricings and Valuations for Tax Purposes

The BEPS program, initiated by the G20 countries in cooperation with the OECD member states, was created with the goal of assisting countries in preventing tax base erosion and the shifting of profits to countries with particularly low tax rates, regardless of the true nature of assessees’ activities in those countries.  

 

The field of global transfer pricing documentation and reporting has revolutionized all aspects of reporting rules, the quality and quantity of data, as well as data transparency between the various tax authorities. This revolution is apparent in the increasing number of cases where tax authorities in different countries decide to increase retroactive collection of taxes, especially in cases where the tax rate previously paid is considered to be unfair.

 

Prometheus Financial Advisory offers its clients tax-related services that add real value, including valuation of companies and intangible assets and transfer prices studies. The Israel Tax Authority has asked the firm to advise it on various economic aspects of transfer pricing in connection with business restructuring. It has also asked the firm to carry out valuations of intangible assets in other capacities.

 

We take great care in supporting our clients throughout all stages of the process, and when necessary, defend the work as part of the client’s dealings with the tax authorities. The firm’s team has vast experience in IP valuations, utilizing advanced information systems and databases as well as unique programs we developed ourselves for internal use.  

 

Services Offered:

  • Valuation of Intangible Assets for Transfer Pricing purposes, in accordance with the applicable laws, rules and regulations set out by the OECD and tax authorities.
  • Valuation of Companies for tax purposes, in connection with restructuring, entry of new partners or the exit of existing partners.
  • Transfer Pricing Studies, the aim of which is to determine the price and profit distribution mechanisms in intercompany transactions.
  • Giving evidence as expert witness in court and participating in discussions with income tax authorities, when necessary.