Transfer pricing services

Analysis of documentary obligations

On 1 January 2019, provisions amending the Corporate Income Tax Act came into force, changing, among others, the rules concerning the determination of the documentation obligation with respect to transfer pricing.

As indicated in Art. 11k par. 2 of the CIT Act, local transfer pricing documentation is prepared for a controlled transaction of homogeneous nature, the value of which, reduced by o Value added tax, exceeds certain documentation thresholds in the financial year.

In view of the above, in order to determine the documentation obligation, revenues or costs of the company are not taken into account, but only the value of the transaction.

As part of our services, we offer analysis of documentation obligations in terms of verification of transactions subject to the obligation to prepare.

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.

Transfer pricing policy

This document provides guidance on the principles for setting transaction prices in transactions with related parties.

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.

Tax audits and tax procedures

Transactions between related parties are subject to high control risk. Within the offered services ICT offers support to entities during tax audits by preparing the client for a potential tax audit, participation in tax proceedings and in proceedings before administrative courts.

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