Transfer pricing

Transfer pricing is an underestimated aspect of running a company. However, the very high penalties for non-compliance with the regulations governing them and the high interest of the tax authorities in this area prove this approach to be wrong. Just how much can be gained from effective transfer pricing assistance is evidenced by the PLN 503 million we have defended for our clients in litigation in this particular area (link to tax litigation practice). We have prepared more than 8,000 transfer pricing documents and more than a thousand comparative analyses for our clients. This has allowed our clients to meet their documentation obligations and justify the marketability of the prices applied by related parties, thus avoiding multimillion-dollar penalties.

The scope of our support covers all stages of intra-group cooperation:

• starting with the modelling of intra-group transactions and the preparation of a transfer pricing policy
• through ongoing support in reviewing their conditions and implementing changes
• periodic documentation of transactions carried out and their reporting
• through to assistance during tax and administrative court inspections and proceedings relating to transfer pricing

As part of the above activities:

• We work with clients to plan new ventures and make changes to related party transactions, supporting them with our experience and providing analysis to optimally arrange intra-group cooperation.
• We prepare legally required transfer pricing documentation, including local files, benchmarks (using renovated databases, including QTPA, Royalty Range, ktMine), master file and TPR.
• We assist clients throughout the process of obtaining an advance pricing agreement (APA).
• We verify the compliance of documents prepared within international groups with Polish regulations and adjust as necessary.
• We provide comprehensive legal assistance in transfer pricing disputes with tax administration authorities, representing taxpayers from the initiation of an audit to the conclusion of administrative court proceedings.

Successful operation in transfer pricing requires both attention to detail and meticulousness in the preparation of documents and analyses, as well as an understanding of the business environment and openness to the client’s needs and an individual approach to their case. In our practice, we combine these elements, providing clients with competent and responsive support.