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Transfer pricing

Since January 1, 2019, the Tax Code of the Republic of Belarus has been changed, legislation in the area of transfer pricing has become closer to world trends and approaches of the OECD. Approaches to control over transfer prices have been changed.

We will help to take timely steps to avoid tax risks, develop a systematic approach to application of transfer pricing in your organization as well as we will provide methodological and practical support in the preparation of transfer pricing documentation.

How can we help?


  • detection of availability of controlled transactions;
  • functional analysis of controlled transactions;
  • assistance in choosing the relevant method of transfer pricing;
  • preparation / update of a comparative study using statistical databases (SPARK, Aamadeus, Orbis, Ruslana, Bloomberg professional and others);
  • preparation of documentation on transfer pricing on the basis of the analysis performed;
  • preparation of documentation / economic justification for transfer pricing;
  • adaptation of documentation on transfer pricing prepared at the group level in accordance with the requirements of the Belarusian legislation.


  • consulting on tax burden planning during business restructuring, mergers and acquisitions;
  • consulting on reducing of transfer pricing risks;
  • optimization of the business model, including the supply chain of goods, works, services both to the local market and beyond it;
  • consulting on tax matters related to transfer pricing;
  • development and implementation of targeted business processes (identification of new analyzed transactions, pricing and control over pricing in the analyzed transactions, collection of documentation).
  • analysis of the possibility of transfer risks realization when using certain business models
  • holding of a training seminar for the employees of the organization on issues of transfer pricing.


  • support in conducting tax audits in the sphere of transfer pricing;
  • examination of tax audit decisions in respect of controlled transactions with a view to the possibility and expediency of contestation;
  • assistance in preparation of arguments for verification findings in case of unlawful decisions.

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