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Transfer pricing
WE TAKE CARE OF THE LEGAL SECURITY OF OUR CLIENTS IN RELATIONS WITH RELATED ENTITIES
We help our clients comprehensively and effectively fulfil their obligations under transfer pricing regulations. At every stage of the project, we provide advice so that the activities in the field of ensuring the arm’s length nature of the transaction support operational efficiency and ensure legal and tax security.
TRANSFER PRICING DOCUMENTATION AND TRANSACTION REPORTING
The documentation of transactions with related parties prepared by us is a careful preparation that will ensure compliance with tax regulations. We also prepare tax documentation for other tax jurisdictions.
Our services include in particular:
- A detailed analysis of the taxpayer’s obligations regarding transfer pricing documentation,
- Classification and grouping of transactions and indication of possible simplifications and documentation exemptions,
- Support in obtaining documents from the Group,
- Preparation of the local file and master file documentation,
- Preparation and assistance in submitting TPR-C, CbC-P, CbC-R declarations,
- Transfer pricing audit including audit of tax documentation, benchmarking analyses, submitted TPR-C information in terms of obligations, as well as completeness and correctness,
- Ongoing support for persons responsible for transfer pricing in large capital groups.
EXAMPLES OF PROJECTS COMPLETED BY OUR EXPERTS:
BENCHMARKING ANALYSES AND VALUATIONS
Our specialised team of economic analysts is responsible for the preparation of benchmarking analyses and valuations.
We work with clients from various tax jurisdictions (Europe, Asia, USA), preparing about 500 market analyses annually for planning and verifying the profitability of transactions.
We prepare analyses using international databases: TP Catalyst, Royality Rates, Bloomberg.
Our offer includes in particular:
- Preparation and regular updating of benchmarking analyses as part of transfer pricing documentation,
- Creating and updating compliance descriptions
- Preparation of benchmarking analyses for future Polish and international transactions (financial, services, goods) and restructuring,
- Calculation of transaction profitability, valuation of specific transactions tailored to the clients’ needs.
EXAMPLES OF PROJECTS COMPLETED BY OUR EXPERTS:
TRANSFER PRICING CONSULTING
Based on OECD guidelines and the requirements of various tax jurisdictions we prepare a number of solutions in transfer pricing advisory.
Our offer includes in particular:
- Preparation of transfer pricing documentation tailored to the requirements of a given country,
- Benchmarking of entities from a selected geographical region while meeting the requirements of a given tax jurisdiction,
- Preparation of a group transfer pricing policy,
- Development of detailed transfer pricing models and settlement models for domestic and international transactions,
- Ongoing legal and tax consultations.
EXAMPLES OF PROJECTS COMPLETED BY OUR EXPERTS:
BUSINESS RESTRUCTURING
Restructuring processes are a challenge in the context of transfer pricing.
Our company offers support in the following areas:
- Analysis of a given transaction in terms of the occurrence of transfer pricing restructuring,
- Analysis of the need for settlements, including the payment/obtaining of remuneration for the transfer of significant functions, assets and risks between related entities (exit fee),
- Adjustment of changes in the transfer pricing model in connection with business restructuring,
- Development of transfer pricing documentation for restructuring and defence file aimed at securing the interests of our clients.
EXAMPLES OF PROJECTS COMPLETED BY OUR EXPERTS:
DEVELOPMENT AND IMPLEMENTATION OF TRANSFER PRICING POLICY
We prepare a Transfer Pricing Policy, which contains detailed guidelines on how to set prices and settlements in intra-group transactions. A well-prepared policy supports the management of intra-group transactions.
Our offer includes in particular:
- Creating settlement models and transfer pricing policies that will be uniformly applied in intra-group transactions,
- Defining the principles, methodology and procedures of settlements in transactions between related parties,
- Development of transfer pricing processes and supervision over their implementation, preparation of contract templates and other internal documents,
- Assistance in making transfer pricing adjustments.
EXAMPLES OF PROJECTS COMPLETED BY OUR EXPERTS:
REPRESENTATION OF CLIENTS DURING TAX AUDITS AND IN COURT DISPUTES
We provide comprehensive support at every stage of contacts with tax authorities during tax disputes
Nasze usługi obejmują w szczególności:
- Verification of the correctness of the prepared transfer pricing documentation, analysis of the financial documentation and documents held before they are submitted to the tax audit,
- Control of local documentation compliance with master documentation,
- Tax risk analysis,
- Analysis of the transfer pricing models used and assessment of the chances of success in the event of disputes with the authorities, taking into account the current approach of the authorities,
- Representation of taxpayers at every stage of tax audits, including the development of an action strategy, preparation of appropriate letters and conducting talks with auditors,
- Representing clients in proceedings before administrative courts at every level of instance.
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