Transfer pricing. Documentation, analyses, defence of tax settlements.
The first educational portal devoted to transfer pricing in Poland. The tax advisors of DMS TAX prepare documentation and benchmarking studies and represent taxpayers in proceedings.
Support at every stage of the documentation obligation.
Applying transfer prices is both a legal requirement and a way of optimising financial results. This is the field we specialise in.
Comparability analyses, market analyses, valuations
We help clients determine the market value of planned transactions between related parties…
See the scope →Transfer pricing audit
Our experts support clients in identifying threats and risk areas in the transactions they carry out…
See the scope →Transfer pricing documentation
Preparing transfer pricing documentation is a formal legal obligation arising from statutory provisions…
See the scope →Transfer pricing advisory
Our experts assist clients with past, current and future matters relating to…
See the scope →Transfer pricing policy
Our experts help clients draw up a transfer pricing policy that provides a consistent, standardised…
See the scope →Tax and court proceedings
We assist our clients with tax and fiscal audits and proceedings, as well as with cases before…
See the scope →Transfer pricing documentation procedure
Our experts support clients in setting up a procedure for managing transfer pricing documentation.
See the scope →Training
We have been running closed, tailor-made training courses and workshops on transfer pricing for years.
See the scope →The price between related parties must be at arm's length.
A transfer price is the price applied in all transactions carried out by entities linked by capital, family or personal ties. The category also covers the transfer price in transactions with entities whose registered office, place of management or place of residence is in a country or territory applying harmful tax competition (a so-called tax haven).
Our portal tells you everything about transfer pricing. We supply the most important and the most recent information on both Polish and foreign regulations and guidelines. It is a continuously expanding knowledge base for practitioners who deal with the subject every day, including managers, accountants, tax advisors, legal counsel and statutory auditors.
Regulations, transfer pricing methods and reporting obligations.
A treatment of transfer pricing topics in the order in which they arise in practice: from establishing relationships and thresholds, through the choice of method and the documentation, to audit procedures and the international dimension.
From assessing the obligation to filing the TPR return.
Assessment of the documentation obligation
We establish which transactions exceed the documentation thresholds and whether exemptions apply, including safe harbour.
Benchmarking study
We verify the arm's length level of prices on the basis of comparable data and the appropriate transfer pricing method.
Local File and Master File
We prepare documentation that meets statutory requirements, with a description of the transaction, a functional analysis and the rationale for the method.
TPR return and statement
We prepare the TPR form and provide support during verification activities and audits if the authority approaches the taxpayer.
Transfer pricing at the meeting point of tax law, finance and management.
Tax and law
Transfer pricing is shaped by national legislation and by international directives and guidelines. Knowing the rules and regulations on the application of transfer prices allows businesses to plan their tax burden and to minimise the related risk.
Finance and accounting
Accounting makes it possible to record transactions between related parties. It allows a company to manage the effect of transactions and decisions on its financial position and assets. It is a tool for monitoring how value is transferred and allocated across the business.
Economics and management
Managing transfer prices makes it possible to minimise the risk arising from transactions with related parties, whether by drawing up a transfer pricing policy, preparing tax documentation or concluding advance pricing agreements. It must be borne in mind that the differing objectives of the individual entities making up the group always have to be taken into account.
Changes in the law and the practice of the tax authorities.
Types of transaction subject to transfer pricing obligations: what you need to know
Transfer pricing rules are a way of protecting the interests of the state by preventing…
How to choose an advisor for transfer pricing?
Transfer pricing is no longer a new topic in tax and financial law, and yet it still…
Transfer pricing: the most common doubts
Transfer pricing is not always met with understanding on the part of business owners.
Transfer pricing: frequently asked questions
Restrictions on transfer prices, a tool for sealing state budget revenue from taxes…
Tax havens and transfer pricing: what you need to know
Transfer pricing rules are a solution introduced on an international scale with the aim of sealing revenue…
Resolving transfer pricing disputes
Between entities related by capital, for example where one holds shares in the other, or by personal ties…
The questions taxpayers ask most often.
What is transfer pricing?
Which entities are related?
Why are transfer prices used?
Who creates the rules on transfer pricing?
How are transfer prices determined?
What does transfer pricing documentation contain?
An audit does not stop at transfer pricing
Audit activities rarely stop at a single tax. The authorities have data from standard audit files, the STIR system and TPR returns, so the verification of transfer prices is often the starting point for questions about VAT, withholding tax or debt financing costs. We prepare documentation in the context of the taxpayer's entire settlement and, once an audit has been opened, the DMS TAX team handles the case across every area the proceedings touch.
The course of audit activities, the powers of the authorities and ways of defending tax settlements are described on kontrolepodatkowe.org. The full range of tax advisory services, from CIT and VAT to restructurings and international taxation, is provided under the DMS TAX brand.
Descriptions of the cases we have handled are collected in the section case studies.
Documentation for the current tax year
Describe your transactions and the structure of your capital group. In reply you will receive a scope of work, a schedule and a quote.