Transfer Pricing 

Our extensive experience has led us to establish a Transfer Pricing competence centre. We offer comprehensive services to large capital groups with regard to the creation of Transfer Pricing documentation and policies. We have successfully represented taxpayers in tax proceedings in which the taxable income was initially determined. When performing analyses, we work not only on Polish data, but also on pan-European or global data. Our work, which is provided at an expert level, includes in particular:

​

• preparation of local and group transfer pricing documentation (Local File and Master File)

• preparation of ex-ante analyses for the determination of transfer pricing policies

• preparation of the so-called Defence File, i.e. documentation presenting arguments for the taxpayer's defence in the event of a possible challenge to the terms and conditions of settlements between related parties

• participation as a representative during the conclusion of prior APA pricing agreements

• representation before tax authorities and Administrative Courts during tax inspections and proceedings in the field of transfer pricing

• preparation of professional benchmarking analyses using statistical measures.

​

​