Transfer Pricing
Full transfer pricing lifecycle for related-party groups: policy design, benchmarking and the statutory documentation Polish rules require. We build files that hold up in an audit and keep intercompany pricing consistent with how the business actually operates.
What this covers
- Local File and Master File preparation to Polish requirements
- Benchmarking studies and comparable searches with periodic updates
- TPR-C and TPR-P reporting form preparation and filing
- Transfer pricing policy design for goods, services and IP
- Intercompany agreements drafting and alignment with actual conduct
- Functional and risk analysis (FAR) for each controlled transaction
- Selection and application of the appropriate TP method
- Safe harbour eligibility for loans and low-value-adding services
- Statutory statement on TP documentation and market-level pricing
- Restructuring analysis and exit charge assessment
- Year-end adjustments and their VAT and customs treatment
- Defence file preparation and support during TP audits
- Threshold monitoring and transaction-grouping analysis
- Group-wide TP training for finance teams
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