Transfer Pricing Services

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About us

The transfer pricing team was established to assist our Clients in managing the transfer pricing risk in their business operations. We have provided services to many international and domestic enterprises, developing and optimising transfer pricing policies for transactions in Poland and co-ordinating several regional transfer pricing projects.

Scope of services
  • Tax planning and optimisation advice to establish and implement the appropriate transfer pricing methodology for international and domestic transactions;
  • Providing recommendations for appropriate valuation of product flows, services and intangible assets in related-party transactions focusing, in particular, on the transfer pricing methodology selected;
  • Analysis of the Client’s business activities to identify major areas of transfer pricing exposure;
  • Developing documentation to support the transfer pricing methodology adopted in inter-company transactions, including the development of a functional analysis (functions & risks);
  • Comparables analysis of independent entities engaged in activity comparable to inter-company transactions concluded by the Client;
  • Providing assistance during corporate tax audits and help in preparing defence documentation supporting the Client’s position;
  • Assistance in filing and negotiating Advance Pricing Arrangements.
Transfer pricing planning

We advise Clients in structuring their activities, both cross-border and domestic, to develop and implement the optimal arrangements of activities. Once the new structure is determined, we assist the Client with implementation, in particular:
  • review of inter-company agreements and recommendations on the wording of fee clauses,
  • review or preparation of transfer pricing documentation,
  • preparation of benchmarking studies,
  • preparation of conversion documentation supporting the change in the inter-company pricing and flows,
  • developing a transfer pricing manual with guidelines concerning the calculation of transfer prices for their accounting and finance staff.

Transfer pricing review

Within a transfer pricing review, we analyse inter-company agreements, transfer pricing statements and internal policies, invoices and supporting documents to highlight any transfer pricing exposure. Where appropriate, we recommend an alternative approach to the structuring of inter-company transactions. In our review, we focus on the Polish operations of a group or we take a multi-company regional approach reviewing the principal flows in the Central Europe Region.

Transfer pricing documentation

Transfer pricing documentation requirements became binding in Poland on 1 January 2001. Failure to comply with these requirements can result in significant penalties. Our transfer pricing team supports Clients in collating transfer pricing documentation and defence files through:
  • Preparation of documentation for all types of inter-company transaction which is both consistent and in compliance with local regulations. This includes the preparation of country-specific risk assessment and country-specific documentation when necessary.
  • Advice regarding transfer pricing documentation already prepared by the Client, in order to ensure compliance with local requirements and consistent disclosure of information.

Comparables study (benchmarking)

Our services in this area include:
  • preparing numerical argumentation to prove that the price determined by the Client is within the required range of comparable prices used in transactions between independent entities;
  • compiling information on independent entities comparable with the taxpayer in terms of their business activity and functions;
  • performing a comparative economic analysis by reviewing all available sources and databases.

Dispute resolution

As Polish tax authorities increase their scrutiny of transfer pricing, companies will be required defend their transfer pricing strategies within a transfer pricing audit. Resolving transfer pricing disputes is difficult due to the complexity of related party transactions.

Using our multidisciplinary team, comprising professionals in tax, accounting and economics, as well as a strong international network to coordinate transfer pricing professionals in jurisdictions worldwide, we are able to provide effective representation through all phases of controversy resolution.

Advance pricing arrangements (APAs)

Advance Pricing Agreements (APAs) are advance agreements on transfer pricing methodologies, entered into by a multinational taxpayer and at least one government administration. APA proceedings provide the opportunity to resolve transfer pricing issues for future years (APAs can be concluded for up to 5 years).

Although APA regulations are new in Poland, we have experience in this area and can assist Clients to reach agreement with the tax authorities.