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The acquisition of shares for cash constitutes a controlled transaction.
On 29.03.2021 The Director of the National Tax Information issued an individual interpretation (0114-KDIP2-2.4010.29.2021.1.RK) regarding the determination of the possibility of exemption from the obligation to prepare transfer pricing documentation. The applicant is...
Who submits TPR information in relation to companies within the Tax Capital Group?
Related entities which are subject to the obligation to submit TPR information are companies forming PGK, and not PGK as a taxpayer. Therefore, each of the companies forming PGK is separately subject to the obligation to submit TPR information in relation to the...
How should transactions be grouped for inclusion in TPR information?
For the purposes of TPR information, a given transaction should be identified as a controlled transaction of homogeneous nature within the meaning of Article 11k(2), (3), (4) and (5) of the Act - i.e. in the same way as in local transfer pricing documentation. A...
About us
The Transfer Pricing Institute supports clients in fulfilling their transfer pricing tax obligations.
We offer services in the scope of:
- preparation of transfer pricing documentation – local and group ones
- determining the market level of transfer prices – conducting comparative analyses with the use of external comparative data
- fulfilment of tax reporting obligations
- reporting of MDR tax schemes
- setting the amount of the compensatory levy – restructuring of activities
- the preparation of an application for an APA.
In addition, the Transfer Pricing Institute organizes workshops and trainings (open and closed) on transfer pricing issues.
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Research conducted by ICT is based on professional databases and information obtained by the institute from government institutions.
In addition, Transfer Pricing Institute organizes trainings (open and closed) on topics related to comparability analysis (eg. benchmark study).
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