Advised the client on the complex transfer pricing issues

Our tax specialists assisted in the preparation of transfer pricing documentation for intra-group transactions of one of the world’s leading mineral fertiliser producers. The issue was complex due to the diversity of intra-group transactions.

Different methods had to be chosen and applied for the purchase of raw materials, the provision of logistics services and the sale of finished products.

Even for finished goods, different transfer pricing methods were applied as external comparable transactions were available for some products and not for others.