Transfer prices

Transfer prices, that is, prices applied in transactions among affiliated entities, are the subject of the growing interest of tax authorities, not only in Poland but all around the world. If tax authorities question the level of these prices, the consequences may be severe, including additional revenue adjustment which may be subject to a punitive tax rate of 50 percent. One of the best ways to eliminate or significantly minimize this risk is to prepare tax documentation which is also referred to as transfer price documentation. 

A natural effect of a company’s development is the expansion of its organizational structure. New entities are set up or taken over to enable expansion on new markets and in new sectors. They can also act as internal centers of services or become research and development facilities. The bigger the organization, the thicker and more extensive the network of mutually affiliated entities. Cooperation and transactions among them are inextricably connected with the issue of transfer prices.  

Transfer prices – the scope of our services:  

• drafting or support in drafting and implementation of transfer price policy; 
• audit of transactions concluded with affiliated entities and transfer prices applied by a company in terms of their arm’s length; 
• evaluation of the potential risk within the applied transfer prices and presentation of methods of its minimization; 
• support in the planning of transactions among affiliated entities in order to guarantee their compliance with the arm’s length principle; 
• analysis of agreements concluded by a company with affiliated entities in terms of the risk within transfer prices and their compliance with the actual course of transactions; 
• verification of a company’s transfer price documentation in terms of its correctness and completeness; 
• drafting of transfer price documentation for every type of transaction; 
• preparation of comparative analyses; 
• support in a company’s preparations for a tax control and during the process; 
• representation in tax proceedings as well as court and administrative proceedings. 

How do we help? 

Our firm offers analyses of transfer prices applied by a company and drafting of comprehensive and professional tax documentation. We provide consulting and propose solutions that enable minimization of the risk that tax authorities will question the applied transfer prices and facilitate the drafting of documentation in the future. Within our legal and tax services, we offer support within the establishment of the transfer price policy and transfer prices themselves.  

We also conduct audits of transactions concluded with affiliated entities and analyze transfer prices applied by a company in terms of their arm’s length. We verify potential risks regarding transactions among entities and present optimal solutions in this respect. We also represent clients during tax controls as well as court and administrative proceedings. 

Why TLhub?

TLhub has extensive experience within consulting services on transfer prices. We draft transfer price policies and verify transfer prices in the context of their arm’s length. We also conduct audits of existing documentation in this respect as well as transactions concluded among affiliated entities. We have experience in the representation of clients during tax controls. 

Do not hesitate to contact us in order to obtain more detailed information.