Transfer pricing regulations govern all cooperation between related parties, specifying the conditions under which such transactions should be made. However, the complexity of these regulations, which are dispersed across various laws (CIT, PIT, VAT, and customs law), makes it challenging for taxpayers to identify all their obligations on their own.
How can we help you?
We offer comprehensive assistance in identifying and implementing transfer pricing obligations, considering possible exemptions and the application of safe harbor principles:
Documentation obligations:
- Local File together with benchmarking analysis
- Master File
Reporting obligations:
- TPR
- CBC-R and CbC-P
- ORD-U
When executing projects, we focus on identifying and managing potential risks (including those related to TPR reporting) to ensure maximum security.
Why is it so important?
Did you know that transfer pricing regulations are not globally harmonized and vary from country to country? Are you wondering whether you are subject to transfer pricing tax regulations in Poland, and if so, whether these obligations have been properly defined and fulfilled?
In Poland, documentation and reporting obligations apply only to related party transactions that exceed statutory thresholds. When these obligations do apply, they must be fulfilled within strict deadlines. Failure to comply can result in severe penalties, including fines of up to PLN 40 million for those responsible for financial matters in companies, including Management Board members.
Selected experiences
We are a specialized team of nearly 50 professionals dedicated entirely to transfer pricing, and we have been serving the market for 20 years.
Get to know us and discover how we provide maximum security for Board Members:
- We provide premium services—over 20 years of operation, none of our documentation or analyses have been formally challenged during audits or APA (Advance Pricing Agreement) procedures, either in Poland or abroad.
- When preparing analyses, we use professional databases (including InfoCredit QTPA, TP Catalyst, Bloomberg, and Royalty Range), ensuring the quality and reliability of the data.
- We continuously identify and help manage potential risks.
We guide you safely through the entire process of fulfilling and reporting your obligations, while also ensuring long-term security.
Contact us
Magdalena Marciniak
Partner | Tax adviser | Head of the Transfer Pricing Practice E: magdalena.marciniak@mddp.pl T: (+48) 665 746 360
Magdalena Dymkowska
Partner E: Magdalena.Dymkowska@mddp.pl T: (+48) 501 108 261
Agnieszka Krzyżaniak
Partner E: agnieszka.krzyzaniak@mddp.pl T: +48 692 558 020
Adrian Mroziewski
Partner E: adrian.mroziewski@mddp.pl T: +48 505 294 041
Marta Klepacz
Partner E: marta.klepacz@mddp.pl T.: (+48) 533 889 036