Transfer Pricing

Transfer pricing is not merely a compliance exercise — it means structuring your intercompany transactions so that they withstand scrutiny while optimizing your tax position.

Our team works with databases covering 180 countries and specialized software. We do not prepare studies simply to meet a requirement — we prepare them to withstand the SRI’s most rigorous review.

Our services

Studies that protect and optimize

A sound study does more than document what has already occurred — it also allows you to structure future transactions to maximize your tax position.

Databases covering 180 countries

We draw on international databases, specialized software and the support of Baker Tilly’s global centers of excellence.

Localization of foreign studies

When a parent company sends a study prepared abroad, it must be adapted to the SRI’s specific requirements. Failing to do so is one of the costliest mistakes companies make.

Advance certainty — APAs with the SRI

An Advance Pricing Agreement removes uncertainty at its root: you and the tax authority agree in advance on how your transactions will be valued.

When must the OPR Annex be filed?

If your transactions with related parties exceed USD 3.000.000, you must file the OPR Annex. The deadline is two months from the due date of your income tax (IR) return.

And the Comprehensive Report?

If your transactions with foreign related parties exceed USD 15.000.000, you must also file the Comprehensive Report, within the same deadline.

Do your related-party transactions exceed $3 million?