Transfer pricing issues raise a number of problems in business practice related to the combination of the desire to achieve business goals and the need to minimize tax risk. We carry out our projects with the aim of achieving both of the above objectives, ie by proposing to our clients effective ways of managing the risk of income estimation by tax authorities, at the same time taking into account the needs of clients, the specificity of their industry and the type of business.

The transfer pricing services we offer include consultancy in the following areas:

Preparation of transfer pricing documentation

• comprehensive implementation of projects in the field of preparing documentation of transactions concluded between related entities;
• verification of transfer pricing documentation prepared by the client;
• advice in creating internal procedures for preparing transfer pricing documentation.

Optimization and risk hedging projects

• implementation of advanced structures in the field of tax planning (using the available optimization tools in the field of transfer pricing);
• consultancy in the field of tax-secure valuation of transactions between related entities;
• development of transfer pricing policies for domestic and international capital groups;
• preparing applications and handling cases regarding the issue of prior pricing agreements (APA);
• giving opinions on the terms of transactions concluded between related parties in order to identify possible risks related to income estimation and proposing alternative solutions leading to tax savings.

Comparative analysis (benchmarking)

• conducting comparative analyzes using the client’s internal data, as well as dedicated databases and analytical tools, in order to confirm or verify the market character of transaction parties’ settlements.

Proceedings regarding transfer pricing

• support and representation during tax proceedings and audits, as well as in disputes with tax authorities before administrative courts regarding the market nature of transactions carried out with related entities, completeness of submitted transfer pricing documentation and other issues related to transfer pricing.