For transactions concluded from 2019 onwards, there is a new option of a safe harbour, under certain conditions, for loans, bonds and services with low added value.
The correct application of the safe harbour exempts the taxpayer from the obligation to perform a benchmarking analysis and eliminates the risk of control authorities undermining the marketability of transactions (income estimation).
The service includes the following:
- Feasibility analysis of applying a safe harbour for a given transaction
- Guidelines for the calculation of prices in accordance with the provisions of income tax laws