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Transfer pricing

We provide assistance in the transfer pricing risk management, thus eliminating the tax risk relating to the transactions between related parties related parties.

Transfer pricing

Transfer pricing (TP) has recently become one of the most significant areas of the tax law. This results from the fact that tax authorities are particularly concerned about the transaction flows among  related parties in order to minimise the risk of using intragroup transactions to manipulate the tax base. Statutory regulations on intragroup settlements have been changing dynamically in recent years, which is particularly challenging for companies and board members. This stems from the liability not only for compliance of the filed information with the facts but also for the ongoing monitoring of compliance with obligations under changing tax regulations.

In order to meet the challenges, the PKF Consult team of experts offers complex support services in the following areas:

  • full outsourcing of the TP compliance,
  • support in the performance of the following documentation obligations:

   - the preparation of the Local File,
   - the preparation of the Master File,
   - the conducting of benchmarking studies,
   - the preparation of the CIT-TP report (TP-R information for transactions made
     after 1 January 2019),
   - the preparation of the CbC report,

  • the support provided to companies during tax audits, representation in disputes with tax authorities and before administrative courts,
  • the support in making advance pricing agreements (APA),
  • the TP audit,
  • the verification of taxpayers’ TP policies as to their compliance with the applicable tax laws,
  • the TP planning.

Detailed information about individual services offered by PKF Consult and statutory documentation obligations can be found under the following links:

1. TP compliance

2. TP advisory

3. TP support litigation

4. TP planning


If you have any questions or concerns - please contact us.

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