Transfer pricing is the subject that requires close attention at the planning stage of each transaction between related parties. The issue of transfer pricing has become a number one priority of all tax office and tax inspection audits and remains the source of the highest tax arrears.

 

Bearing this in mind, our offer includes:

 

  • drawing up transfer pricing documentation with respect to the transactions between related parties in compliance with tax provisions as well as training in this regard,
  • consultancy and assistance in developing necessary documentation and conducting negotiations while concluding advanced pricing agreements (APA),
  • support in verifying compliance of transaction terms with transfer pricing regulations,
  • performing comparability analysis (benchmarking) of transfer prices,
  • assistance in developing transfer pricing-related solutions and procedures (including e.g. a system for updating transfer pricing documentation, collection of source documentation to confirm actual performance of intangible services),
  • drafting analyses on the impact of various objective factors on the financial results of transactions with related parties ("defense file").