A highly dynamic global business environment and growing pressure from tax authorities to collect revenues from every possible source have placed transfer pricing at the forefront of today’s tax and financial issues.
We help our clients better understand transfer pricing and prepare the full set of documentation in accordance with local regulations.
Our work is based on OECD Transfer Pricing Guidelines, the Corporate Income Tax Law, and the Rulebook on Transfer Pricing.

Global Transfer Pricing Service Line

The WTS Global Transfer Pricing Service Line consists of WTS Global member firms from all key countries, engaging professionals with significant experience in transfer pricing, including tax experts, economists, and former tax authority officials.
The network offers a wide range of services, including:

• Conceptual design

• Preparation of global documentation

• Structuring of intellectual property and reorganizations

• Benchmark analyses

• Defense during tax audits

• Representation in court proceedings, litigation, and arbitration

• Preparation of APA agreements

WTS takes a practical approach to developing innovative and pragmatic solutions for clients across various sectors.

Our team in Serbia provides transfer pricing services to taxpayers in Serbia, Montenegro, and Bosnia and Herzegovina.

Preparation of Transfer Pricing Reports

The Rulebook on Transfer Pricing defines the form and content of documentation, submission deadlines, the selection and application of methods, and the determination of the depreciation base if a fixed asset is acquired from a related party.

Mandatory parts of the report include:

• Analysis of the group of related entities to which the taxpayer belongs

• Analysis of the taxpayer’s business activity

• Presentation and analysis of intercompany transactions

• Functional analysis – value chain, activities, and risks assumed

• Selection of method to test compliance with the arm’s length principle

• Conclusion on the need for adjustments to the tax base

• Appendices (database data, intercompany agreements, calculations, benchmark analyses, etc.)

Applicable methods include (and combinations thereof):

• Comparable Uncontrolled Price Method (CUP)

• Cost Plus Method

• Resale Price Method

• Transactional Net Margin Method (TNMM)

• Profit Split Method

• Any other suitable method based on reasonable assumptions

Transfer pricing is not an exact science. The key goal is to arrive at a reasonable estimate of taxable profit in line with the arm’s length principle.

Benchmark Studies and Other Analyses

The arm’s length principle requires related parties to apply prices comparable to those in transactions between unrelated companies operating under similar conditions.

Key selection criteria for comparable companies:

• Independence (no related parties)

• Available financial statements for the last 3 years

• Active business status

• Domestic market search first, then international if necessary

• Exclude companies with consecutive losses in the last 3 years

• Exclude start-ups with atypical cost structures

• Industry classification (NACE Rev. 2)

• Comparable revenue range

Once the list is created, a qualitative analysis follows, including business description review, website content, independence confirmation, and ratio analysis.

Advisory on Pricing in Related-Party Transactions

To minimize risks, taxpayers must proactively plan related-party transactions. Transfer pricing policies can be designed to significantly reduce tax expenses.

We assist with defining and reforming transfer pricing policies.

Preparation of Intercompany Agreements

Intercompany agreements should clearly reflect transfer pricing policies to demonstrate compliance with the arm’s length principle.
We prepare such agreements in accordance with local regulations.

Transfer of Intangible Assets and Intercompany Services

Transfer of Intangible Assets
Intangible assets such as brands, licenses, franchises, know-how, patents, and software are often the basis of profit generation. The division of profit depends on each group member’s contribution.
We identify and value intangible assets, assess creation costs and contributions, and evaluate their impact on financial performance and expected benefits.

Intercompany Services
For services received from related parties, it is necessary to:

1. Document that the services were provided and for business purposes (Article 7a of the Corporate Income Tax Law).

2. Analyze cost allocation and mark-up justification, applying appropriate methods and database references.

Special attention is needed for compliance with foreign exchange regulations (e.g., Article 58 of the Foreign Exchange Operations Law), which prohibits payments above EUR 100,000 without a true contract price or on false documentation.

Our expert team is available to assist you in achieving compliance with all relevant regulations for any type of related-party transaction.