Transfer pricing
We help companies manage risks related to transfer pricing and meet documentation obligations. Our transfer pricing advisory provides support at every stage of executing intra-group transactions, minimizing tax risks and potential issues during audits.
What is transfer pricing?
Transfer pricing refers to the prices used in transactions between related entities, such as those linked by capital, personnel, or family ties. These prices must reflect the conditions that would be established by independent entities operating in a similar market. Transfer pricing regulations aim to prevent the artificial shifting of profits between entities. Our services help mitigate the tax risks associated with transactions between related parties.
Who is transfer pricing for?
Our transfer pricing services are intended for businesses that:
- Conduct transactions with related entities, both domestically and internationally, and must comply with transfer pricing regulations.
- Are required to prepare documentation according to current tax laws.
- Want to minimize risks associated with tax audits and optimize internal processes related to intra-group settlements.
- Undertake large investments or reorganizations that involve significant tax risks.
Our range of support
We analyze transactions between related entities to determine their qualification under transfer pricing regulations and identify potential risks.
We prepare comprehensive transfer pricing documentation in compliance with applicable regulations to ensure compliance with tax law.
We conduct benchmarking analysis to determine whether the conditions applied in intra-group transactions adhere to the arm’s length principle. Using reliable databases, we can accurately compare market prices and margins, allowing for a sound assessment of transactions.
We assist in developing and implementing transfer pricing policies tailored to the specifics of your business and in compliance with legal regulations.
We help prepare and submit APA applications, which provide certainty regarding applied transfer pricing and minimize tax risks. Obtaining an APA can offer tax stability for several years.
We represent clients during tax audits concerning transfer pricing, safeguarding their interests and minimizing the risk of additional liabilities. We prepare legal arguments, provide expert presence, and support communication with tax authorities.
We offer dedicated training for finance and management teams to help them understand transfer pricing rules and implement proper procedures within the company.
Cooperation process for transfer pricing
- Transaction analysis – We review all intra-group transactions to identify those requiring transfer pricing documentation.
- Preparation of documentation – We create full documentation that meets all formal legal requirements, helping your company avoid issues during audits.
- Policy implementation – We assist in implementing appropriate transfer pricing policies, ensuring compliance and optimal management of settlements.
- Audit support – We provide support during tax audits to minimize the risk of negative consequences.
- Team training – We conduct training for key team members to ensure operational compliance and efficiency in managing transfer pricing.
Transfer pricing review
Complete the questionnaire, and our expert will check your transfer pricing obligations and identify any areas of risk during a transfer pricing audit.
We offer a free analysis of documentation obligations, ideal for all companies conducting transactions with related entities.
Benefits for your company
- Risk reduction: Proper transfer pricing documentation minimizes the risk of additional tax liabilities and penalties due to non-compliant intra-group transactions.
- Compliance with regulations: We ensure that all transactions comply with current regulations, reducing the risk of tax audits and penalties.
- Transparency: Our advisory services increase the transparency of intra-group transactions, which is important for both tax authorities and business partners.
- Strategic planning: Through transfer pricing analysis, we help clients optimize their transaction structures in a way that complies with regulations and supports long-term business growth.
Why choose us?
Awarded for our contribution to economic development, commitment to corporate social responsibility, and creation of a strong and recognizable brand.
Recognized for upholding high standards in business operations, guaranteeing top-quality service in 2024.
Awarded for actions based on the principles of corporate social responsibility, with effective policies for employees and clients, as well as numerous social projects.
Ranked in the 2024 Rzeczpospolita tax advisory firm ranking.
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Costs of our support
We support both large enterprises and smaller businesses aiming to grow and gain a competitive edge. If you’re wondering how much you can save and what benefits our collaboration can bring, contact us.
A conversation comes with no obligation and could open the door to significant tax savings.
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What documentation is required?
To meet transfer pricing requirements, large taxpayers need to prepare Local Documentation (Local File) and Group Documentation (Master File), and conduct benchmarking analyses. It is also necessary to complete the TPR-C/P forms and submit declarations confirming the preparation of the required documentation.
Maintaining transfer pricing documentation
Transfer pricing documentation must include a detailed description of transactions, a function and risk analysis, and the valuation methods used. Incorrect pricing can lead to financial penalties, including additional tax liabilities. To avoid issues, companies should regularly update their documentation, taking into account changes in tax laws and their evolving structure.
Importance of benchmarking analysis
Benchmarking analysis is an essential part of the transfer pricing process. It allows for comparing transaction conditions with market realities and is necessary to demonstrate that costs are set in line with industry standards. These procedures are required by tax authorities, making proper benchmarking crucial. This analysis minimizes tax risks and ensures compliance with withholding tax regulations.
Consequences of incorrect pricing
Proper management of transfer pricing and withholding tax is both an obligation and a strategy for minimizing tax risk. Regular reviews of documentation and benchmarking analyses are key to maintaining compliance and avoiding penalties such as withholding tax. Knowledge of current tax requirements and well-prepared documentation is critical to a company’s financial security.
Incorrect transfer pricing can lead to serious financial consequences, including additional tax liabilities, interest on overdue payments, and penalties. Tax authorities can make adjustments and impose withholding tax if they prove that transactions were not conducted under market conditions. These services are part of the offerings from Staniek & Partners, with offices in Gdynia, Kraków, Wrocław, and Warsaw.
FAQ czyli najczęściej zadawane pytania
What is transfer pricing documentation?
When is transfer pricing documentation required?
What are transfer prices?
What are related entities?
What is a benchmarking analysis?
What are tax haven transactions?
What are the methods for setting transfer prices?
What are the penalties for non-compliance with transfer pricing regulations?