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Documentation of transfer pricing

We draw up tax documentation of transfer pricing, covering all transactions with affiliated entities, as well as regarding debts transferred to countries with harmful tax competition.

We concentrate on ensuring the maximum level of tax safety for our clients for transfer pricing, including in particular:

  • drawing up the tax documentation of transfer pricing required by provisions of tax law,
  • development of a policy of transfer pricing and keeping it up to date,
  • gathering and drawing up documentation confirming both transactions as well as the relation of transactions with income generated from activity,
  • estimating the tax characterization of intra-group transactions of affiliated entities,
  • carrying out proceedings within the scope of advance pricing arrangements issued by the Minister of Finance,
  • participation in tax proceedings regarding the correctness of implementation of transfer pricing policies.

When creating tax documentation, we identify as many arguments as possible confirming the market character of transactions with affiliated entities. Clear and transparent principles of cooperation with affiliated entities, together with reliable justification for the solutions employed, significantly limit the probability of disputes with tax agencies.

Defining a policy of transfer pricing takes into account both tax and business aspects. In addition to fulfilling requirements defined in the Act on Corporate Income Tax, the work is aimed at estimating risks related to documented transactions as well as recommending a manner of presenting transactions and a range of arguments that allow for the restriction of identified risks.

The service links elements of strategic analysis of the enterprise with an analysis of its functioning, division and organization of work, employed assets, risks, etc., as well as a comparative economic and financial analysis. In relation to the creation of a policy of transfer pricing, we offer help in establishing secure principles of settling transactions with affiliated entities. We also carry out consultations and trainings for persons responsible for keeping tax documentation.

 

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Audytor-31Mirosław Bogusławski was entered into the register of auditors, maintained by the National Chamber of Statutory Auditors, under number 9796.
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We base our activity on administrative court rulings. The Central Database of Administrative Court Rulings is published on the NSA (Supreme Administrative Court of Poland) webpage NSA.