Transfer pricing

Our specialists develop transfer pricing documentation in order to eliminate tax risk related to the questioning of transaction prices used between affiliated entities. We also represent Clients in disputes with tax authorities and before common courts.

As part of advice on transfer pricing, we offer in particular:

• tax reviews including the analysis of affiliations and conditions of transactions concluded between affiliated entities within the scope required to draft transfer pricing documentation;
• assistance in developing and updating documentation pursuant to Article 9a of the CIT Act;
• verification of tax documentation prepared by the Client, as for its compliance with tax regulations, including in particular the identification of tax risks and exposures as well as the implementation of solutions minimising the aforementioned tax risks and exposures;
• analysis of the concluded contracts as for their compliance with tax regulations related to transfer pricing;
• assistance in determining the method for calculating remuneration;
• assistance in transfer pricing control proceedings, including representation in disputes with tax authorities.