Radiography on the industry
Most of the pharmaceutical companies share the fact that they are inevitably embedded in the social systems of the states in which they operate.
Compared to any other industry, the underlying issue of this industry is largely related to the interdependence of private enterprises with the social, emotional and commercial needs of worldwide societies. Such facts and circumstances can be considered as "market conditions", which certainly have an effect on the transfer prices carried out by companies.
In its guidelines on the application of the arm's lenght principle, the OECD Guidelines provide: "As a general rule, such government interventions should be treated as market conditions in that country and should normally be taken into account when assessing the transfer price of the taxpayer on this market ".
However, the OECD guidelines recognize that "it is clear that a price-controlling country must take into account that these price controls will affect the profits that can be obtained by businesses selling goods subject to these controls."
In order to assess the facts and circumstances of the industry, it should be considered the interdependencies between companies and systems. Also, business risks will have to be taken into account with particular attention to transfer pricing.
How we can help?
Our specialists have extensive experience in preparing transfer pricing documentation for customers in the pharmaceuticals industry.
We are focused on helping companies in the pharmaceuticals industry to solve complex transfer pricing challenges with quality and efficiency. Also, we have created a full range of transfer pricing advisory services to a wide array of clients, including local state owned and private enterprises, central government bodies, and leading international corporations.
Our team is at your disposal with a wide range of custom transfer pricing services for the pharmaceuticals industry, including:
- preparation of transfer pricing files;
- preparation of tailored benchmarking studies;
- preparation of transfer pricing policies;
- support during transfer pricing audits;
- preparation of Country by Country Reports and submission of these reports;
- preparation of Country by Country Report notifications and submission of these notifications;
- management of transfer pricing documentation projects;
- creation of procedures to be applied by each company when performing an intra-group transaction;
- coordination with foreign group companies and external transfer pricing advisers;
- ATIPIC Solutions attended the Tax & Finance Forum 2019 May 30, 2019
- DAC 6 – New EU tax mandatory disclosure rules with regard to cross – border transactions May 13, 2019
- Countries in the European Union that accept the transfer pricing documentation in English language April 12, 2019
- Country by Country Reporting in European Union November 22, 2018
- The role of the financial manager in preparation of the transfer pricing documentation October 12, 2018