The transfer pricing regulations have been in place in the Polish legal system for many years, but it is only in recent years that the tax administration has activated control activities in this area. Currently, the tax authorities have not only a professional team of people at their disposal, but also the necessary technical facilities to identify risk areas and effectively verify controlled transactions. In addition, the evolution of transfer pricing regulations, although it has reduced the obligations towards the smallest taxpayers, has introduced many additional requirements for related parties. Some of the obligations have been additionally subject to criminal sanctions. These obligations invariably apply not only to large international holdings, but also to Polish entrepreneurs.
Although transfer pricing is commonly associated with documentation, this issue is much broader than documentation alone. It is an important and independent risk area, requiring a responsible approach as early as at the stage of planning business activities. Proper and previously undertaken actions, including the introduction of the transfer pricing policy and the necessary procedures to comply with it, make it possible to secure this risk. It is important to remember about the potentially wide range of impact of regulations – the risk area includes, among others, restructurings, which on the grounds of TP also include actual activities, such as transfer of functions or risks between related parties.
For years we have been supporting our clients in fulfilling their transfer pricing obligations. In this respect, we combine our expertise in the area of regulations and practice with extensive experience in the implementation of TP projects. We provide transfer pricing training for tax advisors, auditors and legal advisors /training in spe/. We publish articles in the specialist press.
As part of our services, we analyse the client’s situation in terms of TP’s obligations, prepare a transfer pricing policy, prepare transfer pricing documentation and support in fulfilling reporting obligations. We prepare analyses of financial data (if necessary also with the support of professional benchmarking entities) and assist in their updating. We also provide audit of existing documentation, taking into account various legal statuses over the years, and offer support in the scope of inspections and proceedings involving transfer pricing disputes.
Contact: Mateusz Latkowski, Jakub Wirski