TRANSFER PRICING RISK ASSESSMENT TEST
The Risk Assessment Test does not constitute a full analysis of a company’s specific facts and circumstances.
1 / 14
Country of Incorporation
2 / 14
Does the company have related party dealings relating to intellectual property, services, or financing?
3 / 14
Which industry does the company operate in?
4 / 14
Do related party transactions amount to more than 50% of either Revenues or Costs for the Company?
5 / 14
Does the company have dealings with related parties located in tax havens?
6 / 14
Does the Company have and maintain at least one of the following types of documentation?
• Agreements with Related Parties
• Transfer Pricing documentation
• Defense file
• Transfer Pricing internal policies
7 / 14
Has the company or its corporate group been restructured in any of the last 4 years?
8 / 14
Has the Company incurred operating losses in any of the last 4 years?
9 / 14
Has the company experienced significant swings in its revenue and/or profitability in the last 4 years?
10 / 14
Has the Company amended any of its tax returns during the last 4 years?
11 / 14
Has the Company requested a tax refund during any of the last 4 years?
12 / 14
Are key personnel at the Company knowledgeable of its transfer pricing policies?
13 / 14
Is any related party transaction tested via gross margin methods (i.e., Resale Minus method price or Cost Plus method)?
14 / 14
Does the Company monitor and check its transfer pricing results before year-end?
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