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Regulations, methods and reporting obligations

Definitions, documentation obligations, transfer pricing methods, audit procedures, sanctions and the international dimension.

Transfer pricing step by step

Definition of transfer pricing
Related parties
Controlled transaction
The arm's length principle
Polish legislation
Glossary

Reporting obligations

The documentation obligation
Local transfer pricing documentation (Local File)
Group transfer pricing documentation (Master File)
Statement on the preparation of documentation
TPR
CbC
Transfer pricing adjustment

Transfer pricing risk management

Transfer pricing methods
Transfer pricing analysis
Comparable uncontrolled price method (CUP)
Resale price method (RPM)
Cost plus method
Transactional net margin method
Profit split method (PSM)
Safe harbour

Transfer pricing audits

Administrative and fiscal procedure
Tax sanctions
Criminal sanctions
Fiscal penal sanctions
Sanctions for failing to prepare transfer pricing documentation

Transfer pricing worldwide

APA
International organisations
EU guidelines and reports
Country profiles
Entities from so-called tax havens

Scope of work and quote

Tell us what transactions you carry out within the group. We will indicate the obligations that apply to you and the deadline for preparing the documentation.