Transfer pricing documentation

Transfer pricing documentation is a central element of transfer pricing under Polish tax regulations. Its importance may be evidenced by the fact that the concept of transfer pricing is often directly identified with the tax documentation itself. Considering the purpose of its preparation and the scope of information that the documentation must contain, it is not surprising to attribute such great importance to it.

Entities conducting, as a rule, controlled transactions whose values reach adequate materiality thresholds are required to prepare local transfer pricing documentation for a given tax year (Local file). Local transfer pricing documentation, in addition to descriptions of the transaction itself, its parties, financial data, or the distribution of risks, assets and functions, also includes transfer pricing analysis, in which the price used in the transaction is compared to market prices. In special cases, the local documentation must also include the economic justification of the transaction, in particular a description of the expected economic benefits, including tax benefits.

Moreover, in the case of belonging to capital groups, it may also be necessary to prepare group transfer pricing documentation (Master file). Group documentation contains, in particular, a description of the group, its significant intangible assets, or financial situation, with a particular focus on transfer pricing policy in intra-group transactions.

A dedicated team of PKF Tax&Legal experts will help you meet your documentation obligations, starting from the verification process itself, to comprehensive preparation of all elements of documentation, maintaining the highest quality standard and within the stipulated deadlines.

We provide Transfer pricing and other services throughout Poland in regional offices in Warsaw, Łódź and Poznań, Opole, Wrocław, Katowice, Lublin, Gdańsk and Zielona Góra.