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” Mere knowledge is not enough,
it also needs to be

J. W. Goethe

Transfer pricing

Tax advisory services in the area of transfer pricing are intended to limit the risk of prices applied in transactions with related entities being questioned by tax authorities.

Our advisory services related to transfer pricing include a whole array of services – from examining the actual status, existing relations, contracts and documentation, through restructuring of relation flows, developing tax documentation and analysing the transfer pricing levels.

As part of securing public settlements, we prepare relevant contracts using our international consultation options.

The primary aim of services related to transfer pricing is to ensure tax security of business transactions carried out between related entities.

The other objective is to use the transfer pricing policy as an effective tool for tax planning, which results in tangible effects in the field of corporate finance.

Our services related to transfer pricing include in particular:

  • analysing tax risks related to transactions with related entities,
  • preparing and verifying documentation regarding transactions with related entities,
  • determining the market level of prices on the basis of comparable market data (benchmark analyses),
  • conducting reviews in the field of transfer pricing,
  • developing the transfer pricing policy for capital groups,
  • advising on the selection of appropriate method of determining prices,
  • advising on tax and court proceedings regarding transfer pricing issues,
  • tax planning using transactions between related entities,
  • analysing intangible intragroup services (e.g. licences for trademarks, technologies, know-how),
  • analysing the structure of intragroup costs division and supporting the development of documentation justifying the treatment of expenditure for intragroup services as tax costs.