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We offer you comprehensive support in meeting the new transfer pricing obligations
The new obligations concern the verification of contractors in terms of their settlements with the tax havens, and in particular, checking whether the beneficial owner of payment is located in the tax haven. The scope of obligations is extensive and refers to cost-generating transactions with related and unrelated counterparties; both domestic and cross-border ones. All transactions exceeding PLN 0.5 million in a given tax year are subject to verification.
In each case, verification procedures need to take place and documentation proving that checks were performed needs to be gathered. Depending on results of procedures, it may also be mandatory to carry out an analysis of a beneficial owner or prepare the tax documentation. Tax laws impose an obligation on taxpayers to exercise due diligence in the above-mentioned scope, non-compliance with which is subject to sanctions under the Fiscal Penal Code.
The new obligations may entail an additional and significant administrative burden for companies (in particular when it is necessary to verify a large number of contractors).
What does our support for clients look like in fulfilling the new obligations regarding indirect transactions with tax haven entities?
Stage 1 – Preparation of counterparty verification procedure
We will prepare an internal procedure, the purpose of which will be to define the method of contractors verification and the schedule of performed activities. If the Company has already implemented and carries out any internal processes related to the verification of contractors for other needs - e.g. withholding tax or anti-money laundering (AML) obligations, these procedures will be taken into account during the project.
The result of the work will be a procedure adapted to the internal conditions of the company, and its implementation will allow the company to verify contractors while exercising necessary due diligence in accordance with the obligations resulting from the Act. The procedure will include a template of the contractor's statement on its settlements with tax havens and will be compliant with explanations issued by the tax authorities available at the time of the works.
Stage 2 – Assistance in verification of counterparties
We will verify the company's contractors based on the prepared procedure.
In the first step, the company will be responsible for sending statements to contractors. Then, we will verify the company's contractors on the basis of the received declarations and other data sources.
All work will be carried out taking into account the latest available explanations from the tax authorities and using internal tools and search algorithms developed by us.
The aim of the project is to reduce the tax risk by fulfilling the obligations under Art. 11o of the CIT Act. The wide range of PwC support allows you to reduce your commitment time thanks to the effective use of our IT tools and databases.
The tools and the procedure developed by PwC will allow us to perform the due diligence process in accordance with the requirements of Art. 11o of the CIT Act. The results of our work will be summarized in the form of a report containing key information obtained during the verification.
Stage 3 - Preparation of documentation
Depending on the result of the Stage 2, if it turns out that there is an obligation to prepare tax documentation by the company, we will prepare this documentation as part of the project. Our many years of experience in the preparation of transfer pricing documentation will allow us to carry out this stage efficiently and with the highest quality standards.
Why should you choose our support in fulfilling obligations regarding indirect transactions with tax haven entities?
You receive a comprehensive procedure that can be used in the following years.
You ensure the fulfillment of legal obligations in accordance with the current regulations and guidelines.
You reduce the risk of errors.
You receive reports and documentation useful in the event of a potential tax audit.
Why PwC?
One of the biggest and most experienced transfer pricing teams on the Polish market
Open and proactive approach to customer needs, leveraging on experience from various industries, accumulated in the course of thousands of completed projects
Technological competences, including the use of databases and automated IT tools
International cooperation with foreign PwC offices
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