Transfer pricing
We provide support in fulfilling the obligations related to the execution of business transactions with related entities in the country and abroad, including entities seated in the territory of tax havens, and an overview of previous transfer pricing documentation and its update.
In terms of transfer pricing the services offered by the Chancellery include among others:
• business analysis for obligations related to transfer pricing documentation
• analysis for association between parties of a transaction
• assistance in selecting a method of transfer pricing
• indication of tax risks in transactions between related entities or/and with entities seated in the territory of tax haven
• functional analysis of transaction parties including analysis of functions performed, assets engaged, and risks assumed
• draw up of complete transfer pricing documentation for the years:
◦ until 2016
◦ 2017 – 2018 (Local File and Master File)
◦ 2019 and after (in accordance with amended regulations)
• benchmarking study
• draw up of accompanying documentation i.e. agreements between parties of transaction
• assistance in drawing up a statement on declaration on the preparation of tax documentation
• assistance in the process of application for prior price agreement
• representation before tax authorities