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Transfer Pricing Documentation

Keeping tax documentation of transfer pricing is a legal and formal requirement resulting from tax law regulations.

It concern transactions between affiliated entities or between entities whose seat or management board is located on the territory or in a country applying harmful tax competition (tax havens), whose value exceeds the limits specified in regulations.


Why is it worth preparing tax documentation?

Keeping an optimal version of tax documentation of transfer pricing secures the obligation to keep documentation and minimizes:

Systematic keeping of transfer pricing documentation allows to:

Content of tax documentation of transfer pricing

Tax documentation is a collection of information concerning transactions. It comprises the description of the object and the role of the entities participating in the transaction, the policy implemented and the method of price determination. It has to:

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Documentation versions

The experience gained over the years allowed us to prepare several versions of documentation tailored to clients’ needs, with the purpose to fulfil the obligation to keep documentation.

Each Client may choose a version satisfying his needs from both the factual and financial angle.

It should be borne in mind that the documentation has to describe the actual state of transactions and account for all factors and circumstances which could have had any influence. Therefore, it has to be updated each time the transaction conditions described in such documentation change.

In order to limit to a maximum extent the risk related to transfer pricing we recommend to supplement the documentation with an additional element (not required by tax regulations) – comparability analysis.

Our experience>>

We will be pleased to provide detailed information concerning the obligation to keep documentation. You are welcome to contact us .

Dawid Michalak, PhD
Partner in DMS TAX

© DMS TAX Sp. z o.o. 2014