Transfer pricing

Transfer Pricing documentation          Send Inquiry

If you conclude a transaction with your associated entity, you should compile your transfer pricing documentations in a number of determined situations. Tax regulations define several obligatory components which such transfer pricing documentations must contain. We can assist you in preparing them. By working together with our professionals, the entire process will run fast and efficiently. The methodology we use will make it possible for you to square your Company’s transfer pricing area away, and to reduce the risk of questioning your Company’s prices and estimating income by tax authorities. So, what can we guarantee to you in this area?

• We can verify if you should compile documentation for the particular transaction, and, if so, which particular transactions require such documentation to be compiled by you,
• We can compile your Company’s tax documentation for the transactions you have concluded with your associated entities,
• We can verify any transfer pricing documentation that you have compiled on your own, and we can conduct its tax audit,
• We can adjust your tax documentation, which you have prepared according to the international standard, to the requirements that are in force in Poland,
• We can write official letters addressed to Managements of your particular corporate entities with remarks and suggestions in the transfer pricing area. Although this practice is rarely encountered, we have been convinced on many occasions that it makes it much easier for our Customers to document their future transactions.

Benchmarking          Send Inquiry

Benchmarking analysis is an obligatory part of each transfer pricing documentation. Due to the fact that Polish tax authorities are authorised to estimate their taxpayers’ prices and incomes, the benchmarking analysis can also be a valuable tool used to justify them, and in this way to reduce your tax risks and to help you in determining your price or margin ranges in transactions concluded between your non-associated entities. The benchmarking study we perform is based on statistic methods and financial data from the market. We conduct it in accordance with the methodology as defined in the OECD transfer pricing guidelines and regulations issued by the minister competent for public finance.

Master File and transfer pricing policies          Send Inquiry

If you are a Polish parent company of a corporate group, you must prepare a Master File document for the entire Group. On the other hand, if you are part of a foreign corporate group, you should receive such a document from your Group. Unfortunately, it frequently happens that the Master File is not delivered, or that its contents fail to correspond to Polish requirements. Therefore, it can become necessary for you to prepare your own version of such a document, which, however, is time- and labour-consuming, and, above all, requires specialised expertise. And this is exactly where we can come to your assistance.

Documentation of intangible services          Send Inquiry

Since intangible services are relatively more tax-sensitive than regular goods transactions, we support our Customers in the difficult task of collecting documents which confirm that such intangible services have been completed in order to defend the taxpayer, i.e. the task of compiling the so-called defence file. This is important, as, in many cases, tax authorities strive to classify the expenses that have been incurred, for instance, for management services as not constituting tax-deductible expenses. Nevertheless, it is often the case that such documents do exist, but they are scattered throughout the entire company, because too many people, coming not only from the Accounting Department but also from many other departments, take part in performing a given task. Together with us, you can successfully refute the allegation that relative activities were not completed or were not associated with your incomes. So, what exactly can we provide for you as part of compiling your defence file?

• We can identify and collect documents that justify classification of the expenses you have incurred to purchase intangible services as your tax-deductible expenses,
• We can conduct conversations with your Company’s staff in order to make them aware of benefits that can be obtained from the particular services,
• We can raise awareness among the people who work outside the Finance and Accounting Department, and who are direct recipients of intangible services, that it is of utmost importance for all employees to collect documents which confirm that intangible services have been completed.