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Transfer prices

Transfer pricing is not a science, but an interdisciplinary problem. For the purpose of effective advice in this area, we combine skills in various fields, including taxation, law, and financial and economic analysis.

Paweł Sitnik

Manager
TP Expert

Paweł Sitnik

Manager
TP Expert

Scope of advice

Transfer pricing policy – comprehensive consulting including, among others, the following:

  • development of conditions for the execution of transactions between related parties,
  • determination of functional profiles of entities within a capital group,
  • establishing transfer pricing methodologies
  • Transfer pricing documentation – implementation of projects consisting in the preparation of "local-file" documentation, group "master-file" documentation, CBC reporting

    Transfer pricing analyses – preparation of comparative analyses and compliance analyses (descriptions) for all types of controlled transactions

    TP-R – support in complying with obligations related to transfer pricing information

    Transfer pricing reviews – comprehensive advice to analyse the principles of pricing in controlled transactions, identification of tax risks related to transfer pricing, and determination of documentation obligations concerning transactions between related parties

    Transfer pricing proceedings – support for tax proceedings concerning advance pricing agreements (APAs), mutual agreement procedures (MAPs) and tax audits

    Restructuring within capital groups – comprehensive advice on restructuring (e.g. transfer of production to another entity, change of the business profile, transfer of significant assets) within the capital group, including valuation of remuneration for the restructuring and preparation of full documentation

    Transfer pricing adjustments – advice on how to implement transfer pricing adjustments in transactions between related parties

    IP Box (innovation box) – support in determining the eligible income (necessary to benefit from a reduced tax rate) using transfer pricing methods

    Settlements between the taxpayer and a foreign company, and a plant in a SEZ – support in settlements and determination of the tax liability using the transfer pricing methodology

    Responsibility for the area of transfer pricing – advice on determining the scope of personal responsibility (under the Tax Penal Code) for the execution of transactions between related parties

    Completed projects

    Who we work with

    Responsible partner