Research conducted by ICT is based on professional databases and information obtained by the institute from government institutions.

Transfer Pricing Documentation

The Institute prepares tax documentation of transfer prices by local file and master file as well as tax documentation for low value added transactions. The Institute also provides services related to the settlement of business restructuring transactions, in particular calculates the (estimated) compensation payment (exit payment). If you are interested in our services, please contact us.

Comparability anylysis

We offer assistance in the preparation, updating and verification of comparative analyses whose role is to justify that the conditions mean the level of prices and margins applied by related entities is comparable to the conditions in transactions occurring in comparable transactions concluded by unrelated entities.

In order to prepare the analysis in question, we use specialist databases, including databases used by fiscal control offices.

Reporting of Mandatory Disclosure Rules

We propose our services concerning the obligation to report MDR tax schedules within the scope of:

  • verification of reporting obligations of cross-border tax schemes implemented after 25 June 2018
  • verification of reporting obligations of domestic tax schemes implemented after 1 November 2018
  • preparation of guidelines for the recognition and reporting of tax schemes, and
  • continuous support in fulfilling MDR obligations as a “promoter”.

Transfer pricing policy

As part of the service, we offer the development of coherent, transparent conditions for the execution of transactions between related parties in order to minimize the tax risk in terms of transfer pricing.

Limiting the costs of acquisition of intangible services

As part of the service, we offer verification whether a given cost relates to the acquisition of a service or right, the amount of which is subject to limitation, verification whether a given service or right is not subject to exclusion from the verification limitation and determination of the total amount of costs of services and rights subject to limitation (after taking into account exclusions), calculation of the limit of the amount of “qualified” services and rights.

Pricing agreements (APAs), mutual agreement procedures (MAPs)

Poland’s double taxation conventions (agreements) provide for a MAP mutual communication procedure during which the competent authorities of the contracting states strive to eliminate double taxation.

As part of the service, we offer comprehensive support in negotiating price agreements in transactions with related parties.

Restructuring of activities

As part of the service, we offer comprehensive support in restructuring processes, starting from verification whether a given transfer constitutes a restructuring through determining whether the transfer was made on market terms. We also offer a service in the form of determining the exit fee for transferred functions, assets and risks.

Cost sharing agreements

As part of the service, we prepare and verify cost sharing agreements functioning as follows in the capital groups.

Tax reporting

We offer assistance in meeting the requirements of documentary and reporting obligations regarding tax reporting, as well as auditing and reviewing financial statements prepared in accordance with Polish accounting standards. We offer assistance in completing these declarations as well as verifying already prepared forms.

Capital group audits

We offer services in the auditing of capital groups. This audit is aimed at advising in risk management processes and preventing irregularities as well as gathering knowledge about the status of the capital group and problems in its functioning.

Tax opinions

As part of our service, we offer tax law opinions and interpretations.

We prepare opinions on the tax consequences of occurring and likely to occur in the actual state of affairs presented by the Client.


The Transfer Pricing Institute conducts regular trainings on transfer pricing. The training includes, among others:

  • discussion of current legal acts along with changes, – practical workshops on preparing tax transfer pricing documentation,
  • principles of preparing benchmark studies,
  • tax settlement of transactions made between related entities,
  • fiscal penal liability of entities and persons responsible for tax settlements in capital groups.

The Institute annually organizes tax conferences where the latest regulations on transfer pricing are discussed. In addition to a wide range of open trainings, the Institute’s specialists serve their knowledge and experience also during closed dedicated trainings (both one-day and several days), based on the analysis of issues that you would like to be in a professional, practical and detailed manner. For more details, please visit the Training tab or contact the Institute directly.

Withholding tax

As part of the service, we offer support in the preparation of appropriate documentation to enable the application of exemption / reduced WHT rate.

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