Are you required to prepare a transfer pricing study?

A loan to the owner, goods sold to a sister company or services within the group. Any of these transactions can trigger the obligation to prepare a study.

min read

16/09/2026

VELA team

Man signing a document at a desk while a colleague reviews papers - preparing a transfer pricing study

What does the obligation to prepare a transfer pricing study mean in practice?

If your business:

has transactions with a related legal entity or individual,
grants or receives loans between related legal entities and individuals,
sells goods or services within the group,

you are very likely required to have a transfer pricing study.

Related-party transactions that can trigger the documentation obligation

transactions with a related legal entity or individual,
loans between related parties,
sales of goods within the group,
provision of services within the group.

How can VELA Consulting help with transfer pricing?

Instead of thinking about transfer pricing when the tax inspector arrives or the statutory deadline approaches, you can deal with it on time and without stress.

We can help you:

identify risky transactions, even before you carry them out,
assess whether you are required to hold transfer pricing documentation, i.e. whether you are obliged to prepare a Study/Report.

Preparing a transfer pricing study or report

Once it has been established that you are required to hold transfer pricing documentation and, consequently, to prepare a Study/Report, we:

prepare the complete transfer pricing documentation,
prepare the transfer pricing Study/Report,
propose any adjustments to the tax base (if you contact us before the transaction takes place, the risk of a tax base adjustment arising from these transactions is fully minimised).

A transfer pricing study as preparation for a tax audit

By preparing an adequate transfer pricing study, we help you be ready for a possible tax audit.

Transfer pricing is no longer a “topic for later”

It is now:

a legal obligation,
a potential tax risk,
but also an opportunity to keep your business under control.

In the end, the question to ask yourself is not “Do I need a transfer pricing study?” but “Do I want risk or certainty in my dealings with related parties?”

Not sure whether you are required to prepare a transfer pricing study?

VELA Consulting can help you review specific transactions, assess the documentation obligation and prepare a transfer pricing study or report on time.

If you're not sure whether this applies to you, get in touch and we'll check together.

Request a Consultation

Contents

Example H2

Continue Reading

Articles about the obligations that most commonly arise in connection with this topic.

Advisor pointing a pen at a chart in a report during a meeting with a client

Transfer pricing – a review of the amendments to the RS Corporate Income Tax Law

A transfer pricing study is not a new obligation. What is new is that from 2026 you must submit it to the Tax Administration yourself, without waiting to be asked.

Businessman in a blazer reading documents at a table - reviewing the Corporate Income Tax Law amendments

Amendments to the RS Corporate Income Tax Law: what changes for transfer pricing?

The Law Amending the Law on Corporate Income Tax was published at the end of 2025. The biggest changes concern transfer pricing documentation.

Two colleagues in an office discussing tax documentation at a computer

Transfer pricing: why waiting for the tax inspector is no longer a safe option

“I'll deal with it when the tax inspector asks for it.” This is the most common answer we hear. Under the new law, that approach carries a direct financial risk.