Transfer pricing — From strategy to reporting obligations

Transfer pricing is one of the key areas of tax oversight, especially for corporate groups and related parties. Proper management of related-party settlements is not only a legal obligation, but also an important element in minimizing tax risks.

Our transfer pricing consulting combines legal and financial expertise with market practice. We offer comprehensive support – from the identification of obligations, through the preparation of transfer pricing documentation, to representation during tax audits.

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They trusted us

  • NETGURU

  • Cichy-Zasada Group

  • KOMPUTERRONIK GROUP

  • HBH GROUP

  • HBH GROUP

  • FIBAR GROUP

  • Danabud

  • PIS Piotrowski

Transfer pricing — range of services

Identification of responsibilities and linkage analysis

  • Overview of the client’s ownership and organizational structure.
  • Identification of capital and personal relationships between related parties.
  • Assessment of the obligation to prepare documentation in a given tax year.
  • Qualification of reportable transactions.

Transfer pricing documentation

  • Prepare local (Local File) and group (Master File) documentation.
  • Preparation of benchmark analyses (benchmarks) in accordance with OECD guidelines.
  • Update documentation when regulations or transaction terms change.
  • Develop a description of the significant functions, assets and risks of related parties.

Transfer pricing policy and risk management

  • Development and implementation of transfer pricing policies for capital groups.
  • Advising on shaping the terms of intra-group transactions.
  • Evaluate the compatibility of established prices with the market.
  • Support in negotiations between entities in the group.

Representation and controls

  • Preparation of answers to questions from tax authorities.
  • Representation during tax audits and investigations.
  • Support in disputes over the non-recognition of the transaction value as market value.
  • Responding to the authorities’ findings and making the necessary corrections.

Consulting and transactional valuations

  • Advice on entering into transactions with related parties.
  • Verification of contracts, settlements and invoices in light of documentation obligations.
  • Assistance in estimating the market value of benefits.
  • Securing the correct tax settlement.
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Our clients' industries

IT industry Construction services Automotive E-commerce Media supply Plumbing wholesalers New Tech

Why take advantage of our consulting services?

  • Experience working with equity groups and multinational companies.
  • Knowledge of tax authority practice guidelines.
  • Customized approach – we tailor the documentation to the structure of your organization.
  • Transparency – we inform in advance about obligations and costs.
  • Optimized process – we offer clear pricing for transfer pricing documentation and predictability of operations.
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