Transfer Pricing Documentation

Transfer pricing – this term gives sleepless nights to many entrepreneurs who carry out transactions with affiliated entities or with entities from tax havens (even indirectly!). This is because it is a subject that requires precise rationale for the prices used, and tax audits in this area are extremely tedious and thorough. Moreover, for high-value transactions, transfer pricing documentation must be prepared, and it must be proven that an arm’s length price was applied.

Tax advisory in the field of transfer pricing is one of the favourite topics of our law firm’s specialists, who not only understand business but also perfectly know all the problems and risks encountered by businesses and are able to propose the best possible solutions, taking into account the specific nature of their activities.

Since we specialise in providing comprehensive tax and legal advice to businesses, we know what to pay particular attention to, both when setting prices between related parties and when preparing transfer pricing documentation for these transactions. We have prepared such documents for our Clients on numerous occasions. What’s more – we have successfully defended our clients’ transaction prices during tax audits!

As part of our transfer pricing projects, we offer our Clients, among other things:

– accurate and comprehensive business and economic analysis before determining the transaction price,

– preparation of appropriate transfer pricing documentation (local file and master file), including benchmarking,

– identification of tax risks in related party transactions,

– planning and restructuring of settlements,

– preparation of transfer pricing information (TPR-C/TPR-P/ CBC-P),

– drawing up of requests for individual interpretations,

– representation in a tax audit involving transfer pricing.

Contact us at – – and we will be happy to answer all your questions on transfer pricing and present the full range of our services.