Dominika Tyczka

Tax adviser (Poland)
Associate Partner
Phone: +48 71 733 97 92

Michał Gosek

Tax adviser (Poland)
Associate Partner
Phone: +48 61 624 49 39

Transfer pricing is regulated in domestic law as well as in international directives and guidelines. The knowledge of regulations on transfer pricing and of the practice of tax authorities enables you to manage the enterprise effectively due to appropriate planning, identification of risk areas as well as application of tools which help to minimise those risks while taking into account your business aims. The projects which we carry out are adjusted to individual needs and business approaches. They also minimise the risk in connection with transfer pricing and aim at optimising tax burdens.

Transfer pricing – services in Poland

As regards transfer pricing, we offer in particular the following services in Poland: 

  • tax reviews on transfer pricing including the analysis of connections and terms of transactions between related parties; 
  • analysis of group agreements in terms of their compliance with tax regulations on transfer pricing;
  • assistance in determining the remuneration calculation method (remuneration level) while taking into account the business profile of entities participating in a transaction; 
  • comparative analyses (benchmarking);
  • tax assistance in verifying settlement rules concerning e.g. purchases of intangible services and tax treatment of the corresponding costs;
  • preparation, update or analysis of the obligatory documentation for transactions with related parties in line with Article 9a of the Corporate Income Tax Act (transfer pricing documentation);
  • preparation, update or analysis of complex documentation concerning low value-added services;
  • preparation, adaptation or analysis of transfer pricing policy;
  • assistance in restructuring the allocation of administrative resources within related parties, including: preparation or analysis of agreements on the cost allocation; assistance in determining the remuneration calculation method concerning a specific model of allocation of administrative resources; assistance in determining or verifying the remuneration level in order to ensure it complies with the arm's length principle;
  • representation of related parties in contacts with tax authorities, including: assistance in avoiding double taxation; preparation of applications for advance tax rulings; defence of transfer pricing system;
  • preparation of tax opinions on transfer pricing;
  • training courses, workshops – also at your premises.

More information about Transfer pricing: