Transfer pricing
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 financial 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 ("defence file").