Transfer pricing

• Preparation of transfer pricing documentation addressing the requirements resulting from local tax regulations for all types of transactions subject to inspection;
• Audit of transfer pricing documentation prepared by the Client together with identification of irregularities and identification of tax risks;
• Preparation of the Master File;
• Verification and adjustment of the Master File to the ocal tax regulations

• Preparation of benchmarking analyses / transfer pricing analyses aimed at determining / verifying the arm’s length level of remuneration for various types of intra-group transactions (service, goods, financial, license, rental transactions, etc.);
• Verification of benchmarking analyses prepared by the Group / Client in terms of regulations regarding transfer pricing;
• Preparation of compliance descriptions for unusual transactions.

• Preparation or verification of a model of cooperation between related entities in order to submit an application for an Advance Pricing Arrangement;
• Support in the process of preparing an application for an Advance Pricing Arrangement and developing the necessary documentation;
• Support in negotiations and in the process of obtaining an Advance Pricing Arrangement.

• Support in the preparation / verification of transfer pricing documentation for tax audit purposes;
• Support and representation during tax audit and proceedings regarding transfer pricing.

Smart.TP application:

• Automation of transfer pricing documentation held by the taxpayer for previous tax years;
• License for access to ready-made reference transfer pricing documentation enabling independent self-generation of documentation for the most common types of intra-group transactions;
• Preparation of an individualized tool for self-generation of documentation (including documentation for unusual transactions, configured at the Cleint’s request);
• Archiving of prepared documentation and enabling the use of previous configurations for the purposes of preparing transfer pricing documentation for new transactions.

Smart.TP-R application:

• facilitating the compilation of mandatory transfer pricing information, supporting the completion of the TP-R form;
• verifying the transfer pricing regarding the taxpayer and transactions carried out with related entities;
• integration with the Smart.TP application – automatic completion of the TP-R form based on information included in the transfer pricing documentation;

• Support in the assessment and analysis of restructuring processes carried out between related entities;
• Valuation of exit payments for transfers made between related entities;
• Support in establishing the settlement methodology for planned intragroup transactions from the perspective of reducing TP risks;
• Development or verification of the transfer pricing policy for planned or implemented intra-group settlements;
• Support and advice on transfer pricing adjustments.

• Support in the preparation of the application for initiating the Mutual Agreement Procedure in the case of double taxation, as well as support and representation in international administrative proceedings;
• Advice on the possibility of using safe harbours for financial transactions and services with low added value;
• Support in preparing the CIT-TP form for 2018 and TP-R form from 2019;
• Development of methodologies / procedures / statements regarding the correct identification of relationships;
• Support in analysing provisions regarding the risk of “non-recognizing” or “re-characterizing” of transactions;
• Support with “Permanent establishment” from the perspective of transfer pricing.