Transfer pricing has been in tax administration’s spotlight for years. It has gained even more importance recently as national and international tax law undergoes important changes and new reporting requirements are introduced to increase the transparency of intra-group operations within multinational enterprises.

The Polish tax administration is intent on developing effective instruments to identify non-arm’s-length transactions in an effort to increase the effectiveness of its scrutiny.

All that brings a number of challenges for taxpayers as they strive to implement their business objectives while limiting their tax risks.

WTS&SAJA offers comprehensive transfer pricing support that draws on our long-term experience and the experience of WTS Global. We understand the specificity of our clients’ business and support them in ensuring tax comfort. Our assistance includes:

Transfer pricing planning for new transactions or business ventures:
• Advising on transfer pricing arrangements for single transactions or complex business models
• Building business justification for transfer pricing arrangements: comparability analysis (benchmarking), valuation support
• Formulating / documenting group transfer pricing policies
• Advising on contract terms between associated enterprises
• Advising on MDR compliance for projected transactions or new solutions

Transfer pricing management:
• Transfer pricing audits, tax risk identification and mitigation solutions
• Issuing opinions on the design of related-party transactions or on business restructuring solutions

Transfer pricing documentation – end-to-end project execution or acting as outsourced compliance provider for corporate groups:
• Master file
• Local file
• Transfer pricing analysis & benchmarking studies, including simplified analyses (analizy zgodności)
• Other reporting support, including with CBC Reporting, CBC-P, TPR
• Verifying documentation developed in-house by local company or its group

Business restructuring:
• Advising on optimum TP structures and models aligned with functions of the parties and with value creation in the supply chain
• Implementation support for transfer pricing models: choice of method, comparability analysis, identification of appropriate profit level indicators
• Advice on restructuring compensation
• Restructuring documentation
• Support in obtaining APA

Tax litigation:
• Supporting and representing clients in:
– Tax inspections
– Tax proceedings
– Tax & customs proceedings
– Proceedings before administrative courts
• Support during double taxation disputes in course of mutual agreement procedures

Attribution of profits to permanent establishments

Identification of qualifying income for IP Box purposes

Allocation of income and expenses to special economic zone projects