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Transfer Pricing

Consultancy in transfer pricing is one of our main specializations. The transfer Pricing Department Team has for years supported the Clients in the management of risks resulting from the settlements between the related entities, and fulfilling formal requirements connected with the preparation of the documentation.

We always take into consideration the business concepts of the Clients. We know that optimization of tax obligations, and minimizing the risk of denial of transfer pricing by the tax authorities requires the detailed analyses. Working out the best strategy always includes a company`s individual goals and conditions.

Gained experience and constant development in the area of transfer pricing enabled us to develop the best practice.



Completed projects

Case 1

Comprehensive Policy of Transfer Pricing for national and foreign entities

Issue Comprehensive Policy of Transfer Pricing for national and foreign entities
Analysis The source documents analysis, transaction procedures, ways of documentation, assessment of the likelihood of new transactions, tax risk evaluation.
The effect
of our activities
Standardization of transactions between the companies in a group, and methods of determining remuneration. Tax risk limitation at the stage of tax audit, and provision of information source for subject matter experts. Appointment of an internal team for dealing with the issue in the future.
Client Polish IT group specializing in integration of operational systems.

 


Case 2
Securing documenting obligation

Issue Securing tax documentation obligation during tax audit
Analysis Analysis of a request lodged by UKS [Fiscal Control Authority] preparation of a list of transactions subject to documentation, selection of the most tax risky transactions, and evaluation of the collected evidence connected with the documented transactions, marketing and financial data analysis.
The effect
of our activities
Drafting tax documentation for the selected transactions, and handing it over to tax auditors within 6 calendar days (from Wednesday to Monday). No irregularities in transfer pricing were stated in the post-audit report.
Client Subsidiary company belonging to an energy concern in Wroclaw

 

Case 3
Determining market level of remuneration

Issue Determining market level of remuneration for the lease of the company.
Analysis Financial, technical and market data analysis, comparison of the analysed company`s production capacities with comparable companies, determining fixed and variable remuneration, analysis of civil and tax regulations.
The effect
of our activities
Drafting comparability analysis, contract of lease and rent calculator. Verification of the used accounting model during the transaction execution period.
Client Concrete manufacturer

 

Case 4
Determining market level of remuneration for the activities in the scope of research and development (R&D)

Issue Determining market level of remuneration for the activities in the scope of research and development (R&D)
Analysis Financial, technical and market data analysis, IT market analysis from the perspective of R&D, determining remuneration, analysis of German and national regulations in the scope of taxes, accounting and civil law.
The effect
of our activities
Drafting comparability analysis and agreement for providing services in the area of R&D. Accounting model control on the basis of German tax office expectations.
Client Manufacturer of antivirus software

 

Case 5
Comprehensive safeguarding documentation obligation for transactions between related entities

Issue Comprehensive safeguarding documentation obligation for transactions between related entities.
Analysis Financial, controlling and production data analysis, selection of all transactions subject to documentation in the period of tax liability limitation, evaluation of tax risk, as well as tax and penal consequences for the board of the company in relation to the executed transactions.
The effect
of our activities
Drafting all selected tax documentation, help in drafting the source documentation, company`s employees training in the scope of transfer pricing.
Client A leading manufacturer of chocolates and candies in Poland.

 

Case 6
Preparation of documentation for services inside the group

Issue Preparation of tax documentation for services inside the group for the needs of tax audit.
Analysis Financial data analysis, tax risk evaluation, tax law, and substantive and procedural law regulations analysis, source evidence analysis (including e-mail contents, system data, agreements, statements, memos, etc.).
The effect
of our activities
Preparation of tax documentation, help in verification and supplementation of source documentation, running the case as a legal representative
Client The leading exporter of laboratory equipment in Silesia.

 

Case 7
Individual documentation for services connected with carrying out a public tender

Issue Preparation of individual tax documentation for services inside a group, connected with the realization of public tender.
Analysis Financial and technical (IT) data analysis, tax risk evaluation, financial data analysis of comparable entities, external and internal market data analysis, current and historical contracts analysis, source documentation analysis, interviews with employees.
The effect
of our activities
Preparation of individual tax documentation, help in verification and supplementation of source documentation, presentation of an additional description of the realized transaction for the boards of the companies (confidential information in the scope of tax and penalty risk).
Client Leading manufacturer of software for power systems and public administration.

 

Case 8
Determining the market level of remuneration for renting of production infrastructure

Issue Determining the market level of remuneration for renting of production infrastructure and fixed property parallel to buying production services.
Analysis Financial, technical and environmental protection data analysis, tax risk evaluation, external and internal market data analysis, source documentation analysis, administrative decisions and environmental protection regulations analysis, interviews with the employees.
The effect
of our activities
Preparation of a comprehensive agreement in the scope of transactions inside the group, preparation of tax documentation and practical verification of the implemented accounting model.
Client The group of companies utilizing electronic equipment

 

Case 9
Correction of tax return and overpaid tax refund (CIT)

Issue Correction of tax return and overpaid tax refund (CIT) in connection with and including the transactions with a related entity on the basis of management and counselling agreement as tax deductible expenses.
Analysis Financial, technical and market data analysis, external and internal market data analysis, source documentation analysis, interviews with the employees, analysis of tax regulations with particular focus on tax statute and fiscal and penal tax code.
The effect
of our activities
Preparation of tax documentation, litigation documents, and source documentation for the needs of potential tax audit. As a result of our activities the Client received tax return (CIT) without any legal steps undertaken on the part of tax office.
Client A trading company belonging to the Dutch which produces paints

 

Case 10
Conformity evaluation of group model of transaction accounting

Issue Conformity evaluation of a group model of transaction accounting between related entities on the basis of Polish and European regulations and guidelines on transfer pricing
Analysis Accounting model analysis, financial data analysis, analysis of the influence of the model on the financial report and corporate income tax (CIT), analysis of national and European regulations and guidelines.
The effect
of our activities
Preparation of the opinion indicating the tax and financial risks. The assessment of the model, and recommendation for its change – on the tax and financial level.
Client A company belonging to the German group producing and trading industrial automatic systems.

 

We encourage you to get familiarized with the choice of services provided in transfer pricing, and feel free to contact us.

© DMS TAX Sp. z o.o. 2014