Controlled Transactions Overview | How the SRS Performs Transfer Pricing Adjustments in Practice and How CIT Surcharges Arise
When the State Revenue Service (SRS) initiates a transfer pricing audit, entrepreneurs often expect a discussion regarding the documentation format or specific methodological nuances. However, in practice, the SRS focus is usually much more pragmatic – on whether the company’s financial results correspond to what an independent market participant would achieve under similar circumstances. If […]









