Transfer Pricing Documentation
In today's highly competitive economy, developing a business through collaboration with associated entities often allows companies to better meet existing and future challenges.
However, transactions concluded between related parties are subject to special scrutiny from tax authorities. Income tax regulations impose a specific obligation on such entities to prepare transfer pricing documentation.
It is worth noting that the requirement to prepare such documentation applies not only to entities making sales to a related party, but also encompasses purchase transactions from such entities.
The obligation to prepare transfer pricing documentation also applies to taxpayers engaging in transactions where payments are made, directly or indirectly, to an entity located, resident, or managed in a jurisdiction classified as a “tax haven.”
Within this service, we specifically provide:
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Identification of transactions subject to statutory transfer pricing documentation requirements
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Drafting and preparation of transfer pricing documentation for transactions identified as falling under this obligation
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Support in developing transfer pricing strategies
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Assistance in drafting commercial contracts, with particular focus on transfer pricing matters
Fee calculations for this service are based on an analysis of the Client’s specific factual background and the underlying source documentation provided.
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See also
Tax Advisory
Ongoing Support, Audits, Transfer Pricing, and Tax Proceedings
Scope of servicesOngoing tax advisory
Oto tłumaczenie tekstu na język angielski: Ongoing tax advisory services are provided by certified tax advisors and legal experts specializing in tax law. The delivery format is always tailored to meet each Client’s specific needs. As part of our ongoing tax advisory, Clients receive prompt and concise responses regarding the tax implications of their current […]
Scope of servicesTax Audit
A tax audit is a service performed on an individual Client request. The audit is conducted for the accounting and tax periods specified by the Client.
Scope of servicesDrafting expert opinions and legal positions on tax law
Drafting tax law expert opinions and legal briefs on behalf of our Clients is one of our core services. In accordance with individual arrangements with our Clients, we prepare legal tax opinions on the tax implications of existing as well as potential factual scenarios presented by the Client.
Scope of servicesTax Due Diligence
The main objective of a Tax Due Diligence is to obtain reasonable assurance, as a result of the procedures and activities performed, that the business entity has properly calculated and settled its tax and quasi-tax liabilities during the relevant period.
Scope of servicesRepresentation before tax authorities
Representing our Clients in tax proceedings conducted by tax authorities is one of our core services.
Scope of servicesRepresentation before administrative courts
Representing our Clients before administrative courts is a service performed under a separate assignment or serves as the next stage in an ongoing dispute between our Client and tax authorities, throughout which we have previously provided representation.
Scope of services