Managing tax risks in transfer pricing

Transfer pricing is the subject of increasingly frequent and effective audits. Importantly, these audits are, from a substantive point of view, the most complex and usually targeted (i.e. aimed at specific transactions).

The complexity of transfer pricing regulations, which are scattered across various laws (CIT, PIT, VAT, and customs law), means that not every taxpayer can identify all the transactions that fall under these regulations and understand all their obligations on their own. How can you manage these potential risks?

Enlisting the help of transfer pricing experts can protect your company from risks and ensure your interests are safeguarded. Don’t leave your compliance to chance — reach out to us today and let our expertise secure your business’s future.

What are the benefits to your business?

Identify and manage risks in related-party settlement models.

Minimize the risk of automatic selection for inspection based on the TPR form.

Minimize the risk of questioning the arm’s length prices in related-party transactions. Ensure strong protection in the event of an audit, thanks to analyses whose quality has never been challenged in previous audits.

Protect your settlements from the risk of overestimation and/or additional tax liability. Sanctions from the KKS/CCC can reach up to PLN 40 million, while the Tax Ordinance imposes up to a 30% additional tax rate on underestimated income or overstated losses.

How can we help you?

We assist in identifying and minimizing risks related to transfer pricing for all transactions with related entities, whether they involve company-to-company, company-to-individual, or individual-to-individual relationships.

We tailor solutions to the individual situation and needs. Together with the Tax Litigation Department, we support customers: