In recent years, the number of audits carried out by tax authorities within the area of transfer pricing has significantly increased. Moreover, the mentioned audits have become more detailed. The conditions of individual transactions flows are subject to the meticulous analysis. This includes the calculations of remuneration set in relations between related entities. Also, authorities thoroughly analyze the division of functions, risk and used assets between parties of the transaction.
What is crucial, tax audits do not focus solely on examining the accounts of large international capital groups, but are often targeted at smaller Polish groups of entrepreneurs. Due to the availability of data derived from information on transfer pricing, or even SAF-T (Standard Audit File for Tax) selecting entities for audit and initial verification of inter-group settlements have become much easier for tax authorities.
Considering the above and the high volatility of regulations regarding transfer pricing over the last few years, we offer our support in this key area of settlements. The scope of our support include, among others:
- identification of related entities and transactions which are subject to the obligation to prepare transfer pricing documentation aimed at establishing the scope of TP documentation responsibilities;
- support in preparation, updating or verification of policies and procedures in the scope of transfer pricing;
- preparation of local transfer pricing documents, comparative analyses, and other documents prepared pursuant to the transfer pricing regulations (information on transfer pricing, statements of management boards), and also verification of such documents prepared by the company itself;
- preparation and review of agreements concluded with related entities;
- support in the procedure of applying for APA;
- support and representation in the course of tax audits related to the transfer pricing;
- trainings and workshops on transfer pricing.