In business practice, transfer pricing issues give rise to a number of difficulties in attaining a balance between the desire to achieve business goals and the necessity to minimise the tax risk. Our transfer pricing projects aim to meet both such objectives, by offering our clients effective means of managing the risk of potential assessment of income by the tax authorities, which at the same time take into account our clients’ needs and the specifics of their industry and operations.
Our transfer pricing services include consulting in the following areas:
Preparation of transfer pricing documentation
- comprehensive services relating to development of transfer pricing documentation for related party transactions;
- verification of transfer pricing documentation prepared by our clients;
- assistance in design of internal procedures for preparation of transfer pricing documentation.
Optimisation and protection against tax risk
- implementation of sophisticated tax planning structures (using available transfer pricing optimisation tools);
- advisory services relating to valuation of related party transactions regarded as safe from the tax perspective;
- development of transfer pricing policies for domestic and international capital groups;
- preparation of applications and handling of matters related to obtaining advance pricing agreements;
- evaluation of conditions of related party transactions in order to identify potential income assessment risk and recommendation of alternative solutions facilitating tax savings.
- preparation of benchmarking studies using the client’s internal data as well as dedicated databases and analytical tools, to confirm or verify the arm’s length nature of settlements effected between transaction parties.
Transfer pricing proceedings
- support and representation in tax proceedings, tax controls and disputes with the tax authorities before the administrative courts in cases concerning the arm’s length nature of related party transactions, completeness of transfer pricing documentation submitted by the taxpayer and other transfer pricing issues.