Transfer pricing

Starting from 2013, when the transfer pricing legislation in Serbia has become aligned to OECD and other relevant international standards, AGM differentiated itself as one of the pioneers at the market, bringing the know-how and best practice from other European countries to local companies. From then on, our transfer pricing team, qualified both locally and internationally in this area, supported a vast number of multinational companies, working in Serbia, the Balkans and worldwide, with their transfer pricing and international tax issues. In 2020, AGM established strategic partnership in respect of transfer pricing with Quantera Global, one of the world’s leading independent transfer pricing advisory firms, covering Serbian and Montenegrin jurisdiction.

Going beyond statutory compliance, our team has been privileged to be trusted with engagements concerning tax and transfer pricing planning, assessments and policy-tailoring for entire multinational groups with headquarters worldwide. Our transfer pricing services include:

Preparation of Transfer Pricing Documentation (Master File, Local File, CbCR)

We assist in the preparation of the full set of transfer pricing documentation required under Serbian and international regulations, including Local Files, Master Files, and Country-by-Country Reports (CbCR). Our team ensures your documentation complies with local statutory obligations and aligns with OECD guidelines, allowing seamless cross-border operations while minimizing audit risks.

Preparation of Tailor-Made Benchmarking Studies

Our experts develop custom benchmarking studies to determine arm's-length pricing for intercompany transactions. Using the most eminent and relevant global databases and industry-specific analysis, we provide in-depth studies that support your transfer pricing policies and meet the requirements of tax authorities.

Transfer Pricing Planning

We work closely with you to develop effective transfer pricing planning strategies that align with your business objectives while reducing exposure to scrutiny from tax authorities. Our goal is to structure your intercompany transactions in a way that minimizes risks and ensures optimal tax efficiency across jurisdictions.

Development of Transfer Pricing Methodologies and Policies

AGM supports clients in designing and implementing robust transfer pricing methodologies and policies that align with operational realities and meet local and global transfer pricing regulations. We ensure your policies are sustainable, practical, and audit-ready, helping you maintain compliance and reduce administrative burdens.

Transfer Pricing Due Diligence

Our experts conduct comprehensive transfer pricing due diligence to identify compliance gaps and potential risks in your intercompany pricing arrangements. We provide actionable insights and recommendations to resolve issues, ensuring that your policies are aligned with both local legislation and international standards.

Transfer Pricing Trainings

We offer tailored training programs designed to equip your team with a solid understanding of transfer pricing rules and best practices. These sessions empower your staff to manage transfer pricing documentation, address compliance requirements, and handle intercompany transactions with confidence.

Transfer Pricing Audit Defense

In the event of a transfer pricing audit by the Tax Authorities, AGM provides expert support and representation. Our team works to defend your transfer pricing positions, prepare responses to inquiries, and negotiate with tax authorities to achieve favorable outcomes while safeguarding your organization's interests.