Transfer pricing – comprehensive support for related entities
Increasing globalization and technological advancements mean that companies increasingly operate in multiple markets and focus on specific areas of activity. As a result, the number of transactions between related entities is growing.
For businesses, this means the need to establish the terms of these transactions at the market level, which requires ongoing monitoring of the economic environment and rapid response to its changes.
Our comprehensive tax advice on transfer pricing includes supporting entities in structuring transactions, identifying related entities and obligations, assisting in fulfilling documentation obligations (compliance), and developing procedures that increase tax security and company efficiency.
What is transfer pricing?
Transfer pricing is a tax area that applies to transactions between related entities, but not exclusively. This area also applies to transactions with entities located in so-called tax havens. Regulations in this area aim to limit the shifting of income to lower-tax countries and tax avoidance. Although transfer pricing is often associated primarily with documentation requirements, in practice, effective management of this area impacts the operational efficiency of both individual companies and entire groups of related entities.
Who do transfer pricing obligations apply to?
Transfer pricing obligations apply to:
- related entities and transactions carried out between them,
- Polish taxpayers who carry out transactions with entities from so-called tax havens.
How do we support clients with transfer pricing?
The regulations in force since the beginning of 2019 have introduced a number of new obligations, which are constantly changing. Our goal is not just to fulfill individual orders, but to build long-term relationships. We act as a partner who comprehensively supports clients in managing their transfer pricing.
We provide support in planning and concluding transactions between related entities, identifying risks, and determining opportunities to limit documentation obligations in the field of transfer pricing.
We help identify connections between entities and define documentation obligations in the field of transfer pricing.
We help define transaction terms in accordance with the arm’s length principle and taking into account economic conditions. We conduct benchmarking and compliance analyses using professional databases.
We prepare transfer pricing documentation tailored to the taxpayer’s responsibilities, including local documentation and group documentation.
We prepare information and notifications regarding related entities and transactions: TPR, MDR, CBC-P, CBC-R, ORD-U.
We prepare and support the implementation of TP policies and other internal procedures that ensure compliance with regulations and increase the efficiency of transfer pricing management within the group.
We advise on tax adjustments, providing comprehensive support including determining the validity of the adjustment, the value of the adjustment, and its correct inclusion in tax documents.
We represent clients during tax audits and disputes before tax authorities and administrative courts.
We support you in obtaining price agreements (APAs) and in the process of applying for the initiation of a mutual agreement procedure (MAP).
We verify existing transfer pricing documents, identifying potential errors and risks.
We provide comprehensive support in reorganization processes. We verify whether the event constitutes restructuring under Polish law and determine the market conditions for the entire process. We also assist in determining the amount of the compensation payment (exit fee), if it is required.
Why is it worth using our support?
Experience in national
and international
projects
We support companies operating in various industries, both domestically and internationally.
A comprehensive
approach
to transfer pricing
In our daily work, we combine tax, financial and legal knowledge.
Tax
security
We minimize the risk of errors in documents and help avoid potential disputes with tax authorities.
Full
support
at every stage
From transaction planning, through preparation of documents and information, to representation before tax authorities.
Contact us to talk about cooperation
Contact
59 Złota Street Skylight Building, 14th Floor 00-120 Warsaw, Poland
