Transfer pricing (TP)

We advise on all legal aspects of transfer pricing. Our team comprises experts with significant experience of commerce and work inside the Polish tax authorities, including having drafted transfer pricing legislation on behalf of the Ministry of Finance.

Our advice begins at the transaction planning stage, by ensuring that the terms and conditions agreed between related parties comply with the arm’s length principle. We prepare documentation related to transfer pricing, comparative analyses (benchmarks) and compliance with tax obligations on reporting transfer prices to the tax authorities.

How can we help?

  • Structuring transfer pricing transactions;
  • Selecting the most efficient and secure settlement models;
  • Planning transfer pricing settlements concerning restructuring, financial transactions and intangibles that are difficult to value;
  • Creating transfer pricing policies;
  • Preparing local transfer pricing documentation in compliance with CIT and PIT legislation (Local File);
  • Comparative and compliance analyses;
  • Helping to complete TPR and CBC forms;
  • Preparing group transfer pricing documentation (Master File);
  • Representing clients in APA proceedings;
  • Representing clients in proceedings before the Head of KAS to obtain decisions on advance pricing agreements;
  • Representing clients in transfer pricing inspections;
  • Preparing litigation strategies in the event of any disputes with tax authorities;
  • Providing transfer pricing workshops and training.