Transfer pricing


Recently, both from authorities’ and businesses’ attention to compliance of prices in controlled transactions with arm’s length level has grown worldwide. This attention is especially enhanced due to the implementation of initiatives developed by OECD for fighting tax base erosion and profit shifting (BEPS).

Belarus introduced transfer pricing (TP) rules in 2012. However, during 2012 - 2015 TP control was practically not implemented. The audits performed by tax authorities in that period were mainly focused on controlled transactions with real estate.

TP rules were changed significantly on 1 January 2016. Inter alia, the government established new responsibilities of taxpayers, associated with the need to prepare documentation to substantiate prices applied in the controlled transactions.

Among transfer pricing services that we offer are:

  • analysis of the client’s transactions and identification of controlled transactions;
  • functional analysis of controlled transactions;
  • selection of transfer pricing method to justify applied prices;
  • preparation of TP documentation;
  • analysis of group TP documentation and its adaptation to Belarusian requirements;
  • assistance in settlement of disputes with tax authorities on TP matters;
  • tax consulting on other issues related to application of TP rule.

Providing TP services, we have unique chance to leverage knowledge, experience, skills and resources of global PwC network, which include more than 1 500 transfer pricing professionals worldwide.

Contact us

PricewaterhouseCoopers FLLC

, PwC Belarus

Tel: +375 17 335 40 00

Follow us
Follow us