We assist our clients in preparation of audit-defendable local and global transfer pricing documentation (Local file, Master file, CbC reporting). We have broad experience in preparing tailor-made full documentation package for all types of intercompany transactions, business restructuring and other events.

Transfer pricing documentation prepared by our team can be compliant with:

  • Polish TP regulations (current and previous regulations – for all years open to tax audits)
  • OECD TP Guidelines (format in accordance with OECD BEPS Action 13 requirements)

Our documentation services include:

  • Preparation of full-scope documentation – designed to meet all statutory documentation requirements
  • Preparation of simplified documentation – limited-scope documentation for taxpayers who voluntarily prepare TP documentation as a tool for managing tax risks
  • Verification of documentation prepared at the group level – cost-effective approach for our clients preparing TP documentation on their own; within this scope we aim to make the Client’s TP documentation compliant with Polish TP documentation requirements and we review if the benchmarking analyses prepared by the Client are in line with Polish TP regulations
  • Preparation of multi-country documentation – in cooperation with our Taxand network partners we prepare the TP documentation across multiple tax jurisdictions; these services are designed especially for multinational groups processing TP documentation centrally and at the same time ensuring that specific local transfer pricing documentation requirements are met.