Transfer pricing documentation

We assist our clients in preparation of audit-defendable local and global transfer pricing documentation (Local file, Master file, CbC reporting). We have broad experience in preparing tailor-made full documentation package for all types of intercompany transactions, business restructuring and other events. Transfer pricing documentation prepared by our team can be compliant with:

• Polish TP regulations (current and previous regulations – for all years open to tax audits)
• OECD TP Guidelines (format in accordance with OECD BEPS Action 13 requirements)

• Preparation of full-scope documentation – designed to meet all statutory documentation requirements
• Preparation of simplified documentation – limited-scope documentation for taxpayers who voluntarily prepare TP documentation as a tool for managing tax risks
• Verification of documentation prepared at the group level – cost-effective approach for our clients preparing TP documentation on their own; within this scope we aim to make the Client’s TP documentation compliant with Polish TP documentation requirements and we review if the benchmarking analyses prepared by the Client are in line with Polish TP regulations
• Preparation of multi-country documentation – in cooperation with our Taxand network partners we prepare the TP documentation across multiple tax jurisdictions; these services are designed especially for multinational groups processing TP documentation centrally and at the same time ensuring that specific local transfer pricing documentation requirements are met.

APA – proactive approach to transfer pricing risks

As Crido we offer full range of support in the APA (advance pricing agreement) procedure which is the most effective tool of transfer pricing risk management. Our support covers also the simplified APA procedure, which is the remedy for limitation on tax deductibility of intra-group service and intangible charges.

• We develop strategies for applying for APA based on the level of complexity of transactions while at the same time seeking to minimize administrative costs of the process,
• We prepare complete APA applications, taking into account the type of APA procedure, the nature of transactions and the requirements to present the economic justification (the so-called benefit test),
• We actively support our clients in the APA negotiation process with the tax authorities by moderating preliminary meetings, conducting the official exchange of correspondence, participating in the reconciliation meetings (negotiations) and by monitoring the process.