Transfer pricing

In a dynamically changing business environment and ever-growing number of transactions between related parties being made internationally as well as domestically, the key goal of the Mazars Transfer Pricing team’s advisory is to raise the level of tax security of our Clients’ business and financial transactions.

The support we offer covers a whole spectrum of services from inspecting transaction settlements with related parties and appraising resulting tax risks; including defining transfer pricing policy and choosing the appropriate method of setting transfer prices from a business perspective and in relation to the current international and domestic transfer pricing regulations; to verifying or preparing draft contracts between the related parties and preparing related party transaction documentation (according to art. 9a of the Act on Corporate Income Tax and art. 25a of the Act on Personal Income Tax)

Our help in transaction cost appraisal includes external and internal comparable transaction analyses, which help plan settlements as well as defend certain solutions applied by the group. Based on prior experience we offer support during development and implementation of transfer pricing system solutions / internal procedures (including: compiling and updating documentation, gathering evidence of intangible benefits and/or validating writing them down as tax costs as well as justifying the market transaction and its appraisal), the implementation of which greatly reduces tax risk.

Because of the more and more frequent and more scrupulous transfer price inspections we also offer our Clients support during tax (tax control) inspections / tax proceedings including the technical support of skilled Mazars experts as well as help with preparing documentation and explanations of the taxpayers’ situation for defence purposes. 

We also organize transfer pricing trainings and individual, practical seminars customized to the needs and wishes of the Client. 

To assist multinational enterprises in identifying and comparing the transfer pricing requirements of different countries, as well as CbCR, Mazars has developed two online databases.

To reach the online sites, please click below.

TP Rules 2017

CBC Report 2017

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Related Publication

Transfer Pricing

Transfer Pricing is the price at which goods and services are sold between associated enterprises. As the majority of the international trade takes place between allied enterprises, the Transfer Pricing range is enormous.

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Zmiany w cenach transferowych 2018

Do 30 września 2018 r. większość podatników jest zobowiązania do złożenia oświadczenia o sporządzeniu kompletnej dokumentacji cen transferowych dotyczącej transakcji za 2017 r., która spełnia wymagania określone w polskich przepisach. W przypadku spółek, których obroty przekraczają ustawowe progi, z dokumentacji powinno również wynikać, że transakcje dokonywane z podmiotami powiązanymi mają charakter rynkowy.