Transfer pricing Warsaw – documentation and analysis

Do you carry out transactions between related parties?

Protect yourself in the event of a tax and revenue audit and be confident that your organisation is operating in compliance with current legislation.

Get full support in analysing risk areas, preparing comparative analyses, compiling the necessary documentation and comprehensive transfer pricing advisory assistance.

For 20 years we have been providing comprehensive support for the benefit of businesses across the country.

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Do you carry out transactions between related parties?

If you carry out transactions between related parties and exceed the regulatory limits on transaction amounts, you are required to keep transfer pricing documentation.

Protect yourself in the event of a tax and revenue audit and be confident that your organisation is operating in compliance with current legislation.

Get full support in analysing risk areas, preparing comparative analyses, compiling the necessary documentation and comprehensive transfer pricing advisory assistance.

For 20+ years we have been providing comprehensive support for the benefit of businesses across the country.

Why choose us? The strengths of our tax office.

See the benefits of choosing our accounting office to handle your company’s bookkeeping.

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From specialist advice, through analysis, to document preparation.A group of experienced advisers who specialise in transfer pricing.You can get everything done online, by phone or in our Warsaw office.You will receive support that fully meets the profile and needs of your organisation.

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Transfer pricing “from A to Z”. How will you benefit from our assistance?

We will provide you with the complete set of services with which you will …

Make use of the knowledge and skills of experienced experts

Our advisers will carry out a comprehensive analysis of your business to diagnose possible areas of transfer pricing risk. We will also review the compliance of your documentation with the Transfer Pricing policy and prepare comparative economic analyses.

Develop best practice procedures

We will help you set up and then continuously use secure processes for collecting and updating transfer pricing documentation.

Receive all the necessary documentation

We will be responsible for the preparation of all tax documents related to transfer pricing you will need, for example, during an audit. Apart from them you will also get the necessary support in representation before state authorities.

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How to begin cooperation with our office?

Transfer pricing in 3 simple steps.

1. Contact2. Offer3. Cooperation
Use the “Contact” tab to arrange a meeting during which we will get to know your company’s profile and needs in detail.We will analyse the obtained information in detail and use it to create a tailored cooperation offer.If you accept our proposal we will undertake all the operations related to your company’s transfer pricing and handle the necessary accompanying documentation.

Choose professional support in transfer pricing analysis and determination and the preparation of necessary documents

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What is transfer pricing? Whom it concerns?

The term “transfer pricing” (TP for short) is used to describe the prices that apply between related parties (especially when they operate within the same capital group). These primarily include entities that perform transactions involving the movement of goods as well as the mutual provision of services. This is extremely important, as the transfer pricing level very often determines whether an organisation will make a profit or be forced to accept incurring a loss.

When does transfer pricing apply? Who must report it?

Determining such rates is aimed at counteracting malfeasance related to miscalculation of tax burdens and, as a consequence, exposing the authorities of specific countries to declines in revenue from taxes owed to them. They are used in situations where, for example, a parent company from country “A” buys goods or services from its subsidiary in country “B”.

Transfer pricing calculation. How is it determined and on what amount is it charged?

We will use a simple example to better illustrate how transfer pricing works.

Let us assume that an enterprise has two companies operating in two separate countries. The parent company purchases products from the subsidiary, which it will offer to the final customers for EUR 100,000 each. The tax rates in the parent company’s country are 30%, and 20% in the subsidiary’s country. Let us see how the total tax liability will vary depending on the price at which the parent company buys the goods from the subsidiary.

Example 1. Parent company buys goods for EUR 40,000
In this case, the transfer pricing and tax liabilities of the two companies will be as follows:
Parent company county – (100,000 – 40,000) x 30% = EUR 18,000
Subsidiary country – 40,000 x 20% = EUR 8,000
This means that the total amount of tax liabilities is EUR 26,000.

Example 1. Parent company buys goods for EUR 60,000
In this case, the transfer pricing and tax liabilities of the two companies will be as follows:
Parent company county – (100,000 – 60,000) x 30% = EUR 12,000
Subsidiary country – 60,000 x 20% = EUR 12,000
This means that the total amount of tax liabilities is EUR 24,000.

To counteract malfeasance related to setting excessive prices (which reduce taxation), many countries require companies to use transfer pricing which is consistent with the actual prices applicable in the markets concerned. To prove this, such organisations need to keep proper records.

What is transfer pricing documentation and what does it consist of? When should it be prepared?

The main purpose of this type of documentation is providing proof that the transactions concluded between related parties were carried out in accordance with the general conditions that prevail in the markets concerned. Such transfer pricing documentation should consist of three separate documents, including:

  • transfer pricing documentation containing a description of the taxpayer (with an indication of the structure and scheme of the organisation and information on core business), a description of the transaction (subject, related parties, value and calculation method), a comparative data analysis, and compliance description;
  • group transfer pricing documentation containing a description of the capital group, an itemisation of its intangible assets, a list of significant transactions, and the group’s financial data;
  • a report relating to countries, i.e. data on the group of entities concerned.

This obligation must be fulfilled within 9 months, after the end of the financial year.

Who must prepare transfer pricing documentation?

The requirement to comply with such an obligation is strictly related to exceeding specific amounts of transactions that have been carried out in a given financial year. For those involving the purchase of goods or finances, the threshold is PLN 10 million. For services or any other type of transaction, the threshold is PLN 2 million.

How to submit transfer pricing documentation?

This operation is done electronically using the ePUAP platform. The transfer pricing statement must also be properly signed (qualified signature, personal signature or trusted profile).

How much does it cost to prepare transfer pricing documentation?

The prices of this type of support in preparing transfer pricing documents depend on several factors. In our office, we take into account, among other things, the number of transactions, their amounts, the level of complexity, as well as the urgency of the order in question. Contact our experts if you wish to become acquainted with a detailed price list and how much you will pay for such professional assistance.