transfer pricing

Transfer pricing

Our approach

We view transfer pricing not merely as a formal reporting obligation, but as a key element of tax strategy and risk management. When advising clients, we always consider the broader business and organizational context. Our approach is based on the collaboration of an interdisciplinary team – combining tax, legal, financial, and analytical expertise. This enables us to design solutions that not only meet regulatory requirements but also support the company’s operational and financial goals. Our aim is to ensure that clients feel secure, maintain full control over tax risk, and can focus on business growth.

For whom?

Our transfer pricing advisory services are intended for companies conducting transactions with related parties – both within international and domestic capital groups. We also support businesses engaging in transactions with entities located in so-called tax havens, which may be subject to transfer pricing obligations. We assist in meeting TP documentation requirements, TPR reporting, and leveraging tax reliefs (e.g., IP Box). Regardless of the scale of operations, we support both large capital groups and fast-growing companies that are just building their settlement structures.

In dynamic capital groups, transfer pricing is not just an obligation – it’s a risk management strategy that translates into real financial and reputational security for the company.
Tomasz GalkaPartner, Tax Advisor

Benefits

Working with us is more than compliance. It's access to recognized specialists, a strategic approach to transfer pricing, and real support in situations that require a quick and precise response.

Comprehensive Support and Crisis Readiness

Through ongoing cooperation, clients gain access to experts ready to respond immediately in the event of audits, inquiries, or disputes with tax authorities.

Market-Recognized Experts

The highest level of expertise in transfer pricing is confirmed by, among others, the recognition of Partner Tomasz Gałka in the DGP Tax Advisors Ranking in the Transfer Pricing category. This ensures that your documentation and strategy are overseen by a seasoned expert, acknowledged by the professional community.

Tailored Advisory for Every Business

We go beyond interpreting regulations. Every solution is designed with the client’s business specifics, operational model, and financial systems in mind. As a result, implementations are genuinely useful, aligned with the needs of finance departments, and easy to apply in daily practice.

Services

We offer specialized transfer pricing support in the following areas:

Transfer pricing policy development

We offer comprehensive consulting services, including: developing terms and conditions for transactions between related entities, defining functional profiles of entities within a capital group, and establishing transfer pricing calculation methodologies.

Preparation of transfer pricing documentation

Projects involving the preparation of local files, master files in line with current legal requirements.

Country-by-Country reporting (CbC)

Assistance in preparing and submitting CbC reports, covering global income allocation, taxes, and business activities within capital groups.

Transfer pricing benchmarking analysis

Preparation of benchmarking studies and compliance analyses for all types of controlled transactions, supporting reliable verification of applied terms.

TPR reporting

Support in fulfilling obligations related to submitting transfer pricing information via the TPR form.

Transfer pricing reviews

We conduct comprehensive reviews covering the verification of transfer pricing policy in controlled transactions, identification of tax risks in transfer pricing, and support in determining documentation obligations for transactions between related entities.

Tax and customs-treasury proceedings in transfer pricing

Support during tax proceedings related to Advance Pricing Agreements (APA), Mutual Agreement Procedures (MAP), and customs-tax audits. Learn more about how we support in tax disputes >>

Group restructuring

We provide advisory services for group restructurings (e.g., production transfers to another entity, changes in business profiles, transfers of significant assets) within capital groups. This includes the valuation of restructuring-related remuneration and the preparation of complete documentation.

Transfer pricing adjustments

We advise on how to carry out transfer pricing adjustments in transactions between related parties.

IP Box and transfer pricing

We support clients in determining qualifying income (required to benefit from the reduced tax rate) using transfer pricing verification methods.

Settlements between a taxpayer and permanent establishments or SEZ

We assist in conducting settlements and determining the tax result using transfer pricing methodologies for transactions between the taxpayer and permanent establishments or those operating in Special Economic Zones (SEZ).

Responsibility for the transfer pricing area

We provide advisory services on determining the scope of personal liability (from the perspective of the Fiscal Penal Code) related to transactions between related parties.