transfer pricing - adm solutions

LOCAL PARTNER OF

TRANSFER PRICING & CORPORATE TAXES Unique solutions

„we deliver financial excellence“

Brochure for Transfer pricing services

Belgrade, October 2015

ADM Solutions d.o.o.;VAT 105927009;Register Number: 20494018;Bank account: 205-141462-77


2

Content

Page

PART 1 What we do? 3

PART 2 Understanding of your needs as taxpayer 5

PART 3 Background of key members of our team 6

PART 4 Our main clients in Serbia 7



3

Part 1: What we do?

We are tax and financial advisory

company founded in January 2009

that provides services of

accounting, controlling, tax and

financial advisory. We are local

cooperation partner of WTS

Alliance one of the leading world

tax consulting networks.

With proactive approach we are

trying to offer valued services to

our customers providing more

efficient management of finance in

term of tax advices, reducing costs,

increasing cash flow and control of

the entire business.

We selected a team of

professionals who have significant

experience in serving the largest

companies, performing an audit

and advisory service under local

accounting standards and IFRS,

professionals from top management

level in their previous

engagements. We are confident our

team understands a needs and

business processes of the client’s

and have appropriate skills to fulfil

all expectations by the clients.

In the text that follows we present

our main service lines:

TRANSFER PRICING

The highly dinamic global business

enviroment and increasing pressure

from tax authorities to generate

tax revenues from all sources,

put transfer pricing on the top of

tax and finance issues today.

Our approach to Transfer Pricing

Study preparation is that follows:

Completeness of flexible services according to client’s needs:

study preparation, income tax balance review, continuing

advisory during the year.

Proactive approach – in purpose of advanced defining the prices

that are considered as prices that meet “arm’s length principle”

and avoiding of potential correction of taxable profit.

International methodology and expertise by global WTS team

Real fees based on valuation of long term cooperation

4 KEY COMPENTECES IN PROVIDING THE SERVICES

FINANCIAL CONSULTING

Due diligence reports, Company

valuations, Mergers & Acquisitions,

Business planning, Analysis of key

performance indicators (KPIs),

Preparation of budget and

following achievements, IFRS/IAS

advisory, Actuary reports per IAS

19, Preparation of credit reports,

Support in dealing with banks and

auditors, industry and environment

analysis

ACCOUNTING & CONTROLLING

Preparation of annual accounts, Bookkeeping in line with law on accounting, payroll accounting, Reporting on monthly/quarterly/yearly level: Balance Sheet, P&L Account and other reports, Implementation of internal controls and corporate procedures, Implementation of statutory internal acts, Dealing with auditors.

TAX CONSULTING

Preparation and submission annual

corporate tax return and other

declarations to the tax

authorities, Corporate tax

planning and structuring, Tax

reviews and due diligence reports,

Tax optimization & minimization,

Dealing with tax authorities,

Consulitlng in the field of VAT,

withholidng tax, thin

capitalization, customs, pessonal

taxes etc.



4

Part 1: What we do? (Continued)

GLOBAL APPROACH

WTS advises multinational groups,

internationally active medium-

sized companies as well as

individuals, inter alia in the

following areas: Global Expatriate

Services, Indirect Tax and Energy

Tax, International Tax, Mergers &

Acquisitions, Private Clients, Real

Estate Services, Transfer Pricing.

As a local cooperation partner of

German WTS Alliance, in order to

offer highest quality services, we

supported with their expertise and

valuable support in all our local and

regional engagements.

In the following picture we are

presenting of WTS Network (red

countries – member

companies/blue countries –

partner companies):

WTS teams consist of top

specialists with many years of

experience in industry, consulting

firms and in tax administrations.

Due to our closely coordinated

global network we are used to

provide our clients with a

harmonized approach for their

international business and

transactions.

WTS is present in about 100

countries rendering high quality

tax services. Tax consulting has

been the root of WTS and keeps

on being a core competence.

WTS Alliance world network: Local partners & Member companies

WTS Partners worldwide (2015 annual meeting in Barcelona)



5

Part 2: Understanding of your needs as taxpayer

In the text that follows, our

intention is to present prupose and

basis for TP Study preparation as

well as to underline all important

elements of this proposal. Our

service is based on officialy

regulations of Republic of Serbia.

Legal scope for transfer pricing in

Serbia is defined by following

frameworks:

Law on Corporate Income Tax

Law ("Official Gazette of RS",

no. 25/01, 80/02, 80/02 .

Law, 43/03, 84/04, 18/10,

101/11, 119 / 12 and

47/13/108/13)

Rulebook on transfer pricing

and methods according to the

"arm's length" shall apply in

determining the price of

transactions between related

parties ("RS Official Gazette",

br.61/2013, 8/2014)

Guidelines of OECD

(Organization for Economic

Cooperation and Development)

for the implementation of the

rules on transfer pricing for

multinational enterprises and

tax administrations, which

have been translated and

published by the Serbian Fiscal

Society at July 2010.

In a purpose of those

regulations all companies who

have transaction with related

parties are obliged to prepare

Transfer pricing Study and

submit that to Tax authorities

until end of June for previous

year.

Transactional net margin

method (TNMM)

Profit Split method (PS)

All others appropriate

methods

RELATED PARTIES

A party related with a taxpayer is

natural person or legal entity in

whose relations with the

taxpayer, there is a possibility of

exercising control over or

exerting considerable influence

on business decisions. The

possession of 25% or more or the

largest single portion of shares or

interests shall mean that control

over the taxpayer is possible.

Besides the case referred above,

influence on a taxpayer's business

decisions also exists when a

person associated with a

taxpayer has more than 25% of

votes individually in the

taxpayer's controlling bodies.

The penalties in a case of non-

disclosure transfer pricing in

Income Tax Balance or no

submission of Study are

prescribed in the amount from

100,000 to 2,000,000 Dinars.

Penalties for responsible person

in company amount from 10,000

to 100,000 Dinars. Besides, for

intention for avoidance of tax

payment, if the tax amounts over

150,000 Dinars, person

responsible is to be punished by

prison penalty of six months to 5

years according to the article 229

of Criminal Law.

The Rulebook on Transfer Pricing

defines the form and content of

the transfer pricing

documentation, the selection and

manner of the application of

transfer pricing methods, as well

as the manner of assessment of the

base for the calculation of the

depreciation of fixed assets

acquired in transactions with

related parties.

1. Analysis of Group of

Companies

2. Analysis of Company

Business and Faucal

analysis

3. Functional Analysis

4. Consideration of Transfer

pricing methods used for

transactions

5. Findings and final tax

corrections

6. Appendices

CONTENT OF THE REPORT

According to the Rulebook on

Transfer pricing, following

methods are allowed, including

potential combination of methods:

Comparable Uncontrolled

Price Method (CUP)

Cost plus method

Resale minus method



6

Part 3: Background of key members of our team

In the aim of the highest quality

insurance we selcected a team

with confirmed experience in

serving lagre and multinational

companies, providing them

services of auditing, transfer

pricing, due diligences,

valuations. A short resumes of

the managing team to be

engaged in this project are given

as further text:

Bojan Radojičić is financial

consultant in company ADM

Solutions Limited. By performing

a director role he is responsible

for managing the most complex

projects in the finance

consulting. He has 9 years of

experience in auditing, advisory

and financial management. He

possess a certificate of Faculty

of Law of Belgrade for passed

exam for the application of the

transfer pricing methodology.

He gained professional

experience working in the

international audit and

consulting firm BDO in the

engagements of auditing

financial statements and

financial consulting, as well as

finance director of the

international company Azelis.

BOJAN RADOJIČIĆ

ŽELJKO TURUDIĆ

Mr. Radojicic has been involved

in more than 100 projects, of

which the following significant

audit & accounting projects:

Telekom Serbia, Air Serbia, JP

PTT Serbia, Belgrade Fair DP ,

Paraćinka ad, BS Processor,

Schmitz Cargobull, Football

Association of Serbia.

He was engaged in tax consulting

services for Adecco Outsourcing,

Opportunity Bank, First Data,

Magna Seating, FC Red Star,

Acton Communication, Azeils,

Zastava Tapacirnica, EX ING

Grupa, Le Belier livnica Kikinda,

Coface, FESTO GmbH, Profine

GmbH, Luvata, Ferring

Pharmaceuticals , Trizma and

others.

In addition, he was involved in the

preparation of financial due

diligence for the following clients:

Vital ad, Paraćinka ad, Smederevo

Želvoz and JAT Technics Ltd, as

well as business plans for small

businesses .

He graduated from the Faculty of

Economics in Belgrade 2005 , on

the topic "Business Plan" , and has

an international certificate for the

preparation of business plans

received from the ATA

Amsterdam, for winning fourth

place in the "Business Plan

Regional Competiton 2006". He

attended various international

training courses regarding IFRS,

valuation, corporate finance

management and international tax

in Antwerp, Istanbul, Barcelona

and Munich.

Mr. Željko Turudic is financial

consultant of company ADM

Solutions Limited. He has 6 years

of experience in accounting,

finance and advisory services

provided to international and

domestic clients.

The main clients he served in his

career was: Laguna Group, Delfi

bookstores, Alti – Win Win shops,

New Yorker, Mott MacDonald,

Paneleven Group, Salinen, Eko

furnir, The end of line, Carmeuse,

Vitafoam, ENMON, Cosmic

Development i others.

He has completed Master studies

at the Faculty of Economics in

Belgrade in April 2012, the

Department of Accounting,

Auditing and Finance business,

academic title: Master in

Economics, Master's thesis on the

topic: Financing the growth and

development of small and

medium-sized enterprises, GPA:

9.44 / 10:00. He graduated from

the Faculty of Economics,

University of Belgrade,

He was awarded the Regional

Chamber of Commerce Uzice for

the best student of the Zlatibor

District in economics. He is a

fellow of the renowned Serbian

Business Club "Privrednik" from

Belgrade.



7

Part 5: Our main tax clients in Serbia

Contacts:

ADM Solutions d.o.o.

GTC 19th Avenue

Vladimira Popovica 40

11070 Novi Beograd, Serbia

T: +381 (0) 60 70 330 40

E: [email protected]

WEB: www.adm.co.rs

BOJAN RADOJICIC

Director E: [email protected]

T: +381 (0) 60 70 330 40

ZELJKO TURUDIC

Tax Consultant

Tax Services Department

E: [email protected]

T: +381 (0) 60 70 330 30

GTC 19th Avenue, Belgrade

mailto:[email protected]

mailto:[email protected]

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