Transfer Pricing (TP)

Transfer pricing applies to every company that carries out transactions within a corporate group – including the sale of goods and services, financing and licensing. Today, the tax authorities have sophisticated tools for identifying entities for audit, while penalties for non-compliance can amount to tens of millions of PLN for individuals responsible for a company’s finances.

We provide comprehensive support – from transfer pricing policies and Local File and Master File documentation to TPR preparation and representation during tax audits. We use databases widely accepted by the tax authorities and provide advice on both domestic matters and projects involving foreign entities.

TRANSFER PRICING POLICY

We help you build a consistent model for intra-group transactions, ensuring that transaction terms are properly documented and can withstand scrutiny by the tax authorities.

LOCAL AND GROUP DOCUMENTATION (LOCAL FILE / MASTER FILE)

We prepare transfer pricing documentation in accordance with statutory requirements – on time and with a full understanding of your industry and business model.

BENCHMARKING ANALYSES

We verify whether the prices applied are at arm’s length using recognised databases. Our benchmarking analyses are accepted in Poland and abroad.

TPR AND CBC-R / CBC-P FORMS

We prepare and review reports and forms before they are submitted to the tax authorities. TPR is a key tool used by the authorities to select entities for audit, so it is essential to ensure that it is completed correctly.

SUPPORT DURING AUDITS AND APA PROCEDURES

If the tax authorities have already initiated an audit or you want to secure your position in advance, we represent you in proceedings and handle Advance Pricing Agreement (APA) procedures.

Deadlines you need to remember

• 10 months from the end of the year – preparation of the Local File
• 11 months – submission of the TPR form and ORD-U
• 12 months – preparation of the Master File and submission of CBC-R
• 3 months – submission of CBC-P

Failure to meet these deadlines not only creates a risk of an income adjustment, but may also result in fiscal penal liability for individuals responsible for the company’s finances.