Transfer pricing audit
An audit answers a single question: will your settlements with related parties withstand an inspection. We check whether controlled transactions have been correctly identified and compared against the thresholds, whether the documentation meets statutory requirements and whether the TPR return agrees with the books and with the content of the documentation. The result allows settlements to be corrected before the authority does it.
Scope of the review
- identification of capital, personal and family relationships and of controlled transactions, verification of the documentation thresholds,
- assessment of the completeness of the local file and master file for the years reviewed, together with the functional analysis and the rationale for the choice of method,
- consistency of the TPR return and of the management board's statements with the documentation and the financial data,
- review of the transfer pricing policy and of the procedures for applying it within the group,
- identification of risk areas, an estimate of their scale and proposals for remedial action.
Period covered by the audit
The review covers a single tax year or the full limitation period for liabilities, that is five years for CIT, PIT and VAT. It may be comprehensive or concern selected types of transaction, for example intra-group services, loans, licence fees or transactions in goods.
What the audit does not cover
An audit does not replace a benchmarking study. We examine the arm's length level of prices applied in transactions with related parties as a separate service: comparability analyses, market analyses and valuations.
Deliverable
A report listing the irregularities found, an assessment of risk and proposals for action ordered by urgency. If an inspection is already under way, the report becomes the basis for the line of defence. We describe the course of inspection activities and the powers of the authorities on kontrolepodatkowe.org.