Transfer pricing documentation
One of the key obligations for affiliated entities is to draw up tax documentation (transfer pricing documentation) covering controlled transactions (i.e., activities of economic nature identified based on actual behaviour of the parties), which exceed a specific limited amount, conducted with affiliated companies. Taking this requirement lightly or postponing it until the last minute is […]
Mutual agreement and unilateral adjustment procedure
The development of international capital groups with enterprises in many different countries makes the issues related to transfer pricing inextricably inherent to eliminating double taxation. This issue surfaces in situations of tax authorities in a given country challenging the transfer pricing applied in transactions between a taxpayer and affiliated entities that are tax residents in […]
Allocation of costs/profit to an Establishment
Investing in the form of a foreign Establishment is a common method of running a business on the international scene. However, in relation to transfer pricing, such a business approach requires appropriate (market-based) cost and revenue allocation, between the parent entity and its foreign Establishment. Given the above, we offer: developing a method for allocating […]
Market price level determination
Affiliated entities should shape their mutual transactions and other economic events in such a way, so that the agreed terms correspond to market conditions, in particular, so that the price agreed within such a transaction (so-called transfer pricing) is according to the arm’s length principle. Satisfying these obligations requires conducting comprehensive and complex comparative analyses […]
Reporting obligations related to transfer pricing
Our services in this regard include: support in developing and filing information of transfer pricing (TP-R form). developing CbCR reports (Country-by-Country Reporting, Information on entities making up a group of entities) and CBC-P notifications (Notification on the mandatory provision of information on a group of entities); support in developing an ORD-U (Information on contracts with […]
In-audit consulting
Proper preparation of a company and its employees for a tax audit, and forwarding consistent explanations may be crucial to the results of such an audit. Therefore, considering the services of a professional attorney, who will not only provide the enterprise with substantive support in contacts with the tax office but will also act as […]
Business restructuring
Business restructuring is an inherent element of capital group operations, and, because of their significance and impact on the taxation level of affiliated companies, they focus a great deal of attention from tax authorities. In practice, it is important to identify the transaction subject to transfer pricing requirements among restructuring transactions. Until 31 December 2018, […]
Training in the field of transfer pricing
The training and workshops we conduct in the field of transfer pricing are aimed at sharing the knowledge and experience of our experts with the employees of companies, who are primarily involved in finances and tax settlements. The training materials we use are developed with utmost care and attention to detail, and are fully adapted […]
National e-Invoice System – KSeF
Zajawka
VAT
What for? International trade in goods and the ever-increasing globalisation of the economy, combined with economic openness, significantly affect indirect taxation (VAT, excise and customs duty) that have adopted a highly harmonized form in Poland and the European Union. This means that changes in the legislation and also its application within Europe often immediately impact […]
