New partner in the Taxes practice: Aleksy Miarkowski joins SSW
Aleksy Miarkowski joins SSW Pragmatic Solutions as a new Partner. He will join the Taxes practice and develop our offer in the transfer pricing area.
Aleksy has unique experience combining practice in Polish and multinational consulting firms with policy-making experience in the Polish public administration in the field of transfer pricing. – says Tomasz Wickel, SSW Pragmatic Solutions partner, managing the Taxes practice.
Aleksy provides comprehensive tax advisory in the field of transfer pricing for MNE, Polish capital groups and other related entities. Aleksy runs projects regarding establishing of TP policies and preparation a holistic TP documentation packages, including local file, master file as well as benchmarking studies and other business and comparability analyses. He advises on filing TPR and CBC forms. Aleksy is also responsible for ongoing advisory regarding verification of intercompany settlements in line with ALP and developing corporate procedures in the area of transfer pricing. He represents clients during tax inspections regarding TP and in the APA procedure. He also advises on TP aspects of the IP Box relief, restructuring and financial transactions.
Aleksy is one of the main authors of the transfer pricing regulations in the PIT and CIT Act, that came in force in Poland from 2019. He supervised the implementation of the TPR analytical and IT tool at the Polish Ministry of Finance. As a national delegate within the OECD, he participated in the work on the preparation of guidance for Hard-to-Value Intangibles and Financial Transactions, and participated in the BEPS 2.0 project concerning, i.a. Taxation of the Digital Economy.
He graduated from Faculty of Law and Administration of the University of Warsaw, where he also completed PhD studies in the field of tax law. Aleksy also graduate from IESE Business School and the National School of Public Administration (ARGO Top Public Executive – the equivalent of the Advanced Management Program).