Your group trades with itself across borders, and the Albanian tax authority — like every other — wants proof the pricing is real. We design and document transfer-pricing policies that reflect how your business genuinely operates, ready before the request arrives and defensible when it does.
Documentation is only persuasive when it is true. We build policies and files that describe the real allocation of functions, assets, and risks, so they satisfy the arm's-length standard and withstand audit rather than merely tick a box.
What we advise on.
Policy design
We design arm's-length pricing policies for your controlled transactions, aligned with the OECD framework. A sound policy prevents disputes rather than merely responding to them.
Benchmarking
We prepare the economic analysis and comparables that support your pricing. Credible benchmarking is what turns a policy into a defence.
Local file & documentation
We prepare documentation that meets Albanian requirements and is ready before it is requested. Documentation assembled in advance is far stronger than documentation produced under audit.
Intra-group agreements
We put in place the contracts that reflect and support the policy. When the paperwork and the pricing tell one story, the position holds.
Reporting
We handle controlled-transaction disclosures and filings accurately and on time. Consistent reporting avoids drawing unnecessary scrutiny.
Audit defense
We defend your policy when the authority tests it, from first query to resolution. A file built on substance is defended from a position of strength.
How we work with you.
We start by understanding what your business actually does — who performs the functions, owns the assets, and bears the risks — and price the transactions to match. Our lawyers align the intra-group agreements so the documents and the reality agree.
Our tax and legal teams bring the economic and legal work together into one coherent file. You hold documentation that is ready in advance and able to withstand challenge.
You transact with related parties across borders.
You need documentation ready before the authority asks for it.
Your transfer pricing is under audit.
Transfer-pricing rules apply to transactions between related parties under Law No. 29/2023 "On Income Tax" and the Ministry of Finance's transfer-pricing instructions, which adopt the OECD arm's-length principle and documentation standards. Taxpayers above the relevant thresholds must prepare and, on request, submit documentation, and we prepare files that meet those requirements.
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