Transfer pricing
Transfer pricing documentation is an important element confirming the correctness of prices applied between related entities. Due to frequent changes in regulations, taxpayers should ensure that the documentation they prepare not only reflects actual transactions and calculated prices, but also contains all necessary elements.
Lack of transfer pricing documentation and failure to meet certain requirements result in serious consequences: financial for the taxpayer and criminal and fiscal for the management board or the person responsible for maintaining the books of accounts.
Meeting the requirements contained in the transfer pricing regulations and preparing the correct tax documentation requires the cooperation of a team of experienced lawyers, tax advisors, accountants and even analysts.
We offer comprehensive consultancy in the field of transfer pricing, which aims, among others, at limiting tax risks related to transactions concluded between related entities. We provide assistance in the selection of related entities and transactions covered by the documentation obligation, and in the verification of tax documentation already held. We prepare market analyzes of transactions (so-called benchmarking), we support in the reporting process.
Practice leader
Marzena Kidacka Ph.D.
Services
- Ongoing advice - for all types of business transactions
- Legal and tax opinions - preparation of opinions in the field of transfer pricing
- Transfer pricing analyzes - analysis of links between entities in order to determine entities obliged to prepare tax documentation, analysis of contracts concluded between related entities; selection of transactions subject to documentation obligations
- Transfer pricing documentation - preparation of tax documentation at the Local File and Master File levels
- Transfer pricing policy - development and implementation of transfer pricing policy
- Comparative analyzes (benchmarking) - development of comparative data analyzes justifying the market nature of intra-group transactions
- Training - conducting training in the field of transfer pricing
- Tax audits - advice, substantive support and representation in audits conducted by tax authorities
