Tax / Transfer pricing

Transfer pricing

Transfer pricing, considered as all the settlements and co-operation between related entities, is increasingly becoming a subject of interest for tax inspectors both in Poland and abroad. Taxpayers should exercise due care in establishing and then documenting co-operation between entities related personally or through capital. This will enable mitigation of their tax risk arising from challenges of prices used between related entities.

In addition to mitigation of risk, an efficient transfer pricing policy can help attain business objectives of the entire capital group. Importantly, knowledgeable management of transfer pricing can become a tool for effectively managed businesses.

We provide our Clients with support in taking decisions on managing transfer pricing risk and establishing optimum business solutions by way of e.g.:

  • analysing business operations (in order to identify the main risk areas, especially those connected with the methodology for and level of transaction fees), and proposing actions mitigating the risks identified;
  • preparing a transfer pricing policy that describes the principles of settlements used within a group of related entities;
  • preparing comprehensive documentation required under the Polish Corporate Income Tax Act, as well as documentation supporting individual transactions, e.g. agreements, written procedures, invoices;
  • drawing up business analyses verifying/indicating the market nature of prices used in controlled transactions;
  • supporting Clients in restructuring their operations in accordance with market conditions by way of e.g. identification of restructuring processes, determination of the remuneration rationale and level, preparation of appropriate documentation, and development of new co-operation principles once the restructuring process ends;
  • supporting Clients during tax or fiscal inspections and during appeal or court proceedings;
  • supporting Clients in negotiations with the Ministry of Finance, and preparing price agreements in advance.

Please do not hesitate to contact us.


The end of the month is the deadline for submitting a statement on preparation of transfer pricing documentation for the year 2018.

December 2019 Alert – Transfer Pricing – Important Deadlines!

Tax Alert: Transfer pricing adjustments in practice

Transfer Pricing Alert – listed companies’ new reporting obligations concerning transactions with related parties


Krystyna  Szydłowska

Krystyna Szydłowska

Transfer Pricing Practice Leader

+ 48 22 480 81 00

Elva dressed as a fairy Facebook icon LinkedIn icon