Transfer pricing
TP documentation – regulations change, the problem remains.
In recent years, the scope of TP’s documentation obligations has changed significantly.
Based on our extensive experience, we support clients throughout the entire process – from the identification of controlled connections and transactions, through the preparation of all elements of the required documentation, to assistance in fulfilling their reporting and information obligations.
The number of obligations in the TP area is constantly increasing, as is the level of detail of the required data. Consequently, taxpayers devote more and more time to fulfilling the tasks assigned to them by the legislator, and even so they are often not sure whether the work performed meets all the requirements…
At the same time, the quality of transfer pricing control is increasing, hence it is worth considering entrusting some or all of the transfer pricing duties to us, professionals.
- We prepare transfer pricing documentation, both local and group, we also verify the existing one,
- We develop and then help in the implementation of the correct transfer pricing policy between related entities,
- We carry out individualized transfer pricing analyzes in the form of a comparative analysis or an analysis of the compliance of transaction terms,
- We effectively represent clients in disputes with tax authorities in the field of transfer pricing,
- APA or MAP are also no strangers to us.
First of all, we listen to what is being said to us. The area of transfer pricing requires understanding of your business and skilful transfer of its basic assumptions into the framework of legal regulations, not only in terms of the ‘main transaction’, but also other, additional, seemingly less important ones. That is why we prefer workshop and fact-finding meetings as part of the first step of cooperation, because your business knowledge combined with our know-how becomes a guarantee of efficient fulfillment of mandatory obligations.
We listen, but at the same time we analyze hard data, critically approaching the contractual state in confrontation with the actual execution of the transaction, thanks to which we are able to identify the basic and slightly more hidden risks of TP.
Better safe than sorry. A related entity is obliged to submit tax documentation at the request of the authorities within 7 days. And it's not about working days. It's important that these 7 days don't actually turn out to be "full of work"! Hence, it is really worth taking care of preparing the "Local File" in a reliable manner, within the originally set deadlines.
We will respond quickly.