QUICK TRANSFER PRICING REVIEW

Are you part of a capital group and conducting business in multiple countries, including Poland? Are you planning to expand your business into Polish market? Are you wondering how to meet transfer pricing requirements?

Our expert team is here to streamline a process of transfer pricing compliance. As a comprehensive tax advisor, we can offer extensive services in the area of transfer pricing (Local file and Master file documentation, Transfer Pricing Analysis, TPR-C reporting and CBC reporting etc.).

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Transfer pricing tax review

Changing legislation and intensified tax audits have made transfer pricing requirements in Poland increasingly important. Tax authorities now have precise tools for selecting entities for audits. With TPR forms, MDR reporting, and CBC information, they can more accurately examine transfer pricing issues and identify potential irregularities.

If a taxpayer operates within a capital group and conduct related-party transactions of a significant value, it probably must fulfil a series of transfer pricing compliance obligations. On a top of that, it is good practice for taxpayers to establish, monitor, and review their transfer pricing processes, considering the size and complexity of their transactions and the level of risk involved. Such a proactive approach helps in identifying and mitigating tax risks effectively.

How can we help?

Crido can conduct a quick TP audit covering following aspects:

✅ Support in identifying entities classified as related parties and / or tax havens under Polish transfer pricing regulations, including cases where significant influence is exerted,

✅ Identification and grouping of transactions, considering homogeneity criteria and eligibility for exemptions::

• identifying transactions subject to transfer pricing obligations (i.e. local file, TP analysis, TPR-C form, etc.),
• identifying non-obvious transactions — economic events that, based on current regulations, our expertise, or prevailing interpretative practices, may be classified as transactions subject to transfer pricing documentation requirements (Local File) but sometimes escape taxpayers’ attention,

✅ Formal review of existing Local File, Master File, and benchmarking analyses for selected types of transactions to assess compliance with Polish transfer pricing regulations and identify any formal deficiencies,

✅ Verification of data presentation in the TPR form and evaluation of its consistency with the information provided in Local File and benchmarking analyses,

✅ Analysis of the TP model and policy: review of the Group’s business model regarding the role of individual entities and their functional profiles (considering the functions performed, assets involved, and risks assumed), as well as the evaluation of the applied transfer pricing method and the approach to conducting benchmarking analyses.

✅ Identifying transfer pricing risks and possible methods of limiting and mitigating them.

Why choose CRIDO?

Accuracy & Risk Mitigation: Conducting a TP tax review offers several benefits, including reducing tax risks by identifying and correcting potential issues before audits, ensuring compliance with regulations to avoid legal disputes, improving financial management and resource allocation, and increasing transparency through accurate transaction documentation.

Expertise and Experience: With a team of over 40 highly qualified experts, we offer deep industry knowledge and diversified skills. The high quality of our work is recognized by numerous awards and distinctions, confirming our reputation as a trusted advisor.

Involvement of Partners & Managers: Our partners and managers, each with many years of experience, are directly engaged in every phase of the project. This ensures top-tier quality, efficiency, and a strategic approach to achieving your goals.

Proactive Updates & Regulatory Insights: Through active participation in legislative processes, we stay ahead of regulatory changes, ensuring that your business is always compliant and well-prepared for evolving tax and transfer pricing requirements.

Contact us today to learn more about how we can assist you to achieve your business goals involving Poland in a safe way.