Transfer pricing across borders: our international competencies

How well do you know MDDP’s Transfer Pricing Team? Did you know that this year we are celebrating the 20th anniversary of both MDDP and our Transfer Pricing Team? Over the years, we have built extensive experience and international expertise, which have brought us to where we are today:

Almost 50 professionals

• We are a team of almost 50 professionals dedicated exclusively to transfer pricing,

Broad knowledge

• Our experts have diverse backgrounds: in economics, law, finance, accounting (including ACCA qualifications) as well as in statistics and econometrics,

International experience

• We are a domestic company, but transfer pricing is inherently international. From the beginning, we have extensively developed our international expertise. As a result, for almost 10 years, we have been successfully overseeing and implementing full-scope transfer pricing projects from HQ level.

We provide a premium service that gives maximum safety and security

• Throughout our 20-year history, our benchmarking analyses have consistently remained unchallenged during audits or Advance Pricing Agreement (APA) procedures, both domestically and internationally. This track record underscores our commitment to maintaining robust standards and ensuring compliance.

We are local, but our support is global

Why is this important? Because business is international, a fact recognized by the Minister of Finance, who issued an order on 6 May this year to establish a new department – the Department of International Tax Policy. Its responsibilities will include transfer pricing and the attribution of income to foreign permanent establishments. Additionally,  the Department for Large Business will coordinate the implementation of the Globe Anti-Base Erosion Rules (GloBE rules) in KAS.

What might this mean in practice?

• Tax authorities are becoming increasingly specialized in the area of transfer pricing,
• The Ministry of Finance is also considering international regulatory initiatives and incorporating them into its activities.

At MDDP, we understand that transfer pricing cannot be isolated from important topics that are being widely discussed and gradually implemented globally and in Poland:

• Public CbC-R, the obligation for large companies to make their income tax reports public – we already have regulations in force in Poland requiring the publication of the CbC-R and submission to the KRS. This obligation was introduced through amendments to the Accounting Act and other laws. The new regulations will apply for the first time to the income tax report for the financial year beginning after 21 June 2024, i.e. most taxpayers will be subject to it for the first time for FY2025;
• GloBE, the principles that aim to establish a minimum level of effective business taxation of large Multinational Enterprises (MNEs) globally – the long-awaited draft act was released on 25 April 2024;
• ESG, including analysis of how ESG activities can change business strategy, supply chain and even business model;
• on-going international work on, among others, the TP Directive (as part of the BEFIT package), which aims to harmonise TP rules at EU level from 2025 (in recent days the deadline was brought forward, as it was originally intended to be 2026) or the so-called Amount B (under Pillar One), which will affect the activities of wholesale distributors.

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Building competence, including in these areas, enables us to provide tangible support to our clients in their international business development with maximum security. It is worthwhile to learn more about us and see how our transfer pricing models streamline business scaling.