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").