Transfer Pricing
Advisory Services
In today's global economy, national borders have largely ceased to be relevant to the conduct of business by international firms. For the tax authorities of specific countries, however, those same borders are becoming increasingly important as they realize how transfer pricing can impact tax revenues. As a result, transfer pricing legislation and documentation requirements are becoming more stringent day by day, while the fines and penalties for noncompliance are likewise growing. This makes transfer pricing a vital issue to all international companies, requiring planning on a global level.
Advisory Services
In today's global economy, national borders have largely ceased to be relevant to the conduct of business by international firms. For the tax authorities of specific countries, however, those same borders are becoming increasingly important as they realize how transfer pricing can impact tax revenues. As a result, transfer pricing legislation and documentation requirements are becoming more stringent day by day, while the fines and penalties for noncompliance are likewise growing. This makes transfer pricing a vital issue to all international companies, requiring planning on a global level.
Our Services
Review of Related-Party Transactions
Analyze the terms and conditions of related-party transactions; evaluate the methodology used to establish transfer prices; identify risks and suggest strategies for risk-exposed transactions; review contracts and internal guidelines for setting transfer prices, incorporating economic analyses, invoices, and other supporting documentation.
Analysis of Expenses for Intangible Services
Analyze expenses for management services, technical or marketing support (including cost-sharing contracts), trademark licenses, know-how and software, as well as loan-related expenses; verify the rationale for taxdeductibility, including review of contracts, invoices, and supporting documentation for services received; perform "reasonableness review" of expense volume versus associated benefits; and determine withholding-tax liability.
Contracts for Intangible Services
Draft contracts for intangible services when the existing contracts, if any, incur tax risks.
Art. 9a Documentation
Prepare and update obligatory documentation for transactions with group companies pursuant to provisions of Art. 9 of the Corporate Income Tax Act; analyze relevant client-prepared documentation.
Tax Audits
Provide assistance and support during tax audits; prepare relevant arguments and documentation to support the taxpayer's position, including Art. 9a documentation; conduct training courses in transfer pricing, including price-setting methodologies, preparing and updating Art. 9a documentation, and preparing staff for tax audits.
Benchmarking
Compare market-level prices or margins used in related-party transactions with available information about similar transactions carried out by comparable third parties, including business type, functions performed in the transaction, risks faced, and assets involved; assist in preparing argumentation to prove the prices determined by the taxpayer are market-level.
Other
Custom-tailor services to the client's individual needs.
Please contact us:
Jacek Bajger
Partner
jbajger@kpmg.pl
Monika Palmowska
Senior Manager
mpalmowska@kpmg.pl
Janusz Wachowski
Senior Manager
jwachowski@kpmg.pl
<< back
- Review of Related-Party Transactions
- Analysis of Expenses for Intangible Services
- Contracts for Intangible Services
- Art. 9a Documentation
- Tax Audits
- Benchmarking
- Other
Review of Related-Party Transactions
Analyze the terms and conditions of related-party transactions; evaluate the methodology used to establish transfer prices; identify risks and suggest strategies for risk-exposed transactions; review contracts and internal guidelines for setting transfer prices, incorporating economic analyses, invoices, and other supporting documentation.
Analysis of Expenses for Intangible Services
Analyze expenses for management services, technical or marketing support (including cost-sharing contracts), trademark licenses, know-how and software, as well as loan-related expenses; verify the rationale for taxdeductibility, including review of contracts, invoices, and supporting documentation for services received; perform "reasonableness review" of expense volume versus associated benefits; and determine withholding-tax liability.
Contracts for Intangible Services
Draft contracts for intangible services when the existing contracts, if any, incur tax risks.
Art. 9a Documentation
Prepare and update obligatory documentation for transactions with group companies pursuant to provisions of Art. 9 of the Corporate Income Tax Act; analyze relevant client-prepared documentation.
Tax Audits
Provide assistance and support during tax audits; prepare relevant arguments and documentation to support the taxpayer's position, including Art. 9a documentation; conduct training courses in transfer pricing, including price-setting methodologies, preparing and updating Art. 9a documentation, and preparing staff for tax audits.
Benchmarking
Compare market-level prices or margins used in related-party transactions with available information about similar transactions carried out by comparable third parties, including business type, functions performed in the transaction, risks faced, and assets involved; assist in preparing argumentation to prove the prices determined by the taxpayer are market-level.
Other
Custom-tailor services to the client's individual needs.
Please contact us:
| KPMG Tax M.Michna sp.k. ul. Chłodna 51 00-867 Warsaw Tel: +48 (22) 528 1165-71 Fax: +48 (22) 528 1159 |
Jacek Bajger
Partner
jbajger@kpmg.pl
Monika Palmowska
Senior Manager
mpalmowska@kpmg.pl
Janusz Wachowski
Senior Manager
jwachowski@kpmg.pl
<< back
