Transfer pricing

Why does it pay to use our services?

If your company fails to keep transfer pricing documentation, it may be liable to a penalty income or corporation tax rate of 50%. This rate is applies to the difference between the income estimated by tax authorities and the income reported by your company’s related parties.

Tax authorities may request you to provide such documentation during any tax inspection and you will have only 7 (seven) days within which to provide it. This short time period means that it is practically impossible to prepare a complete set of transfer pricing documentation. It is, therefore, advisable to consider preparing it before it is too late. Consult our specialists for support with such documentation.

What are related parties?

There are two categories of ties between companies: capital and personal ties (which include both domestic and international ties) and family, employment-related and property ties (these are only domestic in nature).

However, the terms ‘related party’ and ‘ties’ are not clearly defined in tax regulations. This, unfortunately, means that it is more likely for your company to be required, by law, to prepare transfer pricing documentation. Take care of it sufficiently in advance!

What is the transaction value that requires transfer pricing documentation?

In addition to ties, the value of transactions between related parties is important.

The following four limits are imposed by law:

EUR 100,000: this applies to companies (not partnerships) and is the limit of transactions not exceeding 20% of your company’s share capital.
EUR 30,000: this applies to the supply of services or the making available of intangible assets.
EUR 20,000: this applies if the payment in a transaction is made to an entity established in a tax haven jurisdiction.
EUR 50,000: in all other cases.

Each of the above amounts is the value of transactions over a period of twelve months and is to be converted into PLN using the average exchange rate published by the National Bank of Poland on the last day of the tax year preceding the year in which the transactions were made.

How can we help you?

You already know that by preparing your transfer pricing documentation early enough, your will be able to avoid some unpleasant situations. We can prepare or review your documentation based on the applicable tax regulations. You can also rely on our advice on any related activities, including negotiations and transactions.

Our experienced experts will also prepare a transfer pricing policy for you. This will define the terms of cooperation between your company and your related parties. Obviously, this policy will reflect the methods and principles in place at your organisation.

Do you need to assess the financial risks related to your method of calculating prices in transactions with your related parties? Are you considering a particular transfer pricing method and need some advice? Working together, we will certainly find the right solution.