Transfer pricing is one of the key areas of expertise of our Tax Team. We support companies in effectively identifying and managing their transfer pricing obligations, ensuring compliance with the law and minimising tax risks. Our comprehensive advice covers both the preparation of complete transfer pricing documentation and the fulfilment of transfer pricing reporting obligations, as well as strategic planning of transactions between related entities and defence in the event of a tax audit. We provide transfer pricing support both locally and globally, working with BDO offices around the world.

Our transfer pricing services include in particular:

• Analysis of transfer pricing documentation obligations,
• Preparation of local and group transfer pricing documentation (Local File and Master File),
• Verification of the compliance of local and group documentation (Local File and Master File) with Polish regulations and its appropriate adaptation to Polish regulations,
• Preparation of comparative analyses (Benchmarking studies) and compliance analyses,
• Reporting for transfer pricing purposes (TPR-C / TPR-P forms, Country-by-country Reporting),
• Support in transfer pricing restructuring (Restructurings),
• Determining taxable income in Poland for foreign companies operating in Poland through a foreign establishment (Permanent Establishment),
• Assistance and advice on concluding advance pricing agreements (APAs) and mutual agreement procedures (MAPs),
• Support during tax audits in the area of transfer pricing and preparation of documentation supporting the taxpayer's position,
• Creating and implementing transfer pricing policies,
• Analysing the taxpayer's activities to identify the main areas of transfer pricing risk (transfer pricing reviews),
• Support in the preparation of source documentation for intangible services,
• Ongoing advice on transfer pricing.