Do you see challenges in getting pricing right in related party transactions? Are you feeling the growing pressure from tax authorities and the need to adjust your company's transfer pricing policy to the applicable regulations? Are you concerned that the lack of appropriate transfer pricing documentation may expose your organization to tax risk and fiscal penalties? Do you want to be sure that your company's transactions are in line with the arm's length principle and at the same time optimally adapted to your business needs? The right approach to transfer pricing is not only legal compliance, but also the foundation of your business' stability and security.
Together, we will guide you through the entire process — from a detailed transfer pricing analysis to the effective implementation of a policy that supports your business growth. We offer practical solutions precisely tailored to the specifics of your industry, ensuring full compliance with tax authority requirements while aligning with your key business objectives. With our expert knowledge and experience, we support not only the preparation of transfer pricing documentation but also the identification of potential risks and the implementation of strategies to minimize the impact of any future tax disputes. We also assist with Advance Pricing Agreements (APA) and Mutual Agreement Procedures (MAP), providing clarity and tax certainty in cross-border transactions. By working with us, you gain a reliable partner committed to ensuring compliance and optimizing your transfer pricing processes.
I am a licensed tax advisor and serve as a director in the transfer pricing team. I bring extensive professional experience, including work at the Ministry of Finance, the National Revenue Administration, as well as in tax advisory, where I have had the opportunity to support industry leaders in the area of transfer pricing.
I specialize in conducting transfer pricing analyses, preparing tax documentation, developing benchmarking studies and TPR forms, and reviewing business models from a transfer pricing perspective. My expertise also includes identifying transfer pricing risks and designing strategies and policies within capital groups.
I represented Poland at OECD meetings during the work on the OECD Transfer Pricing Guidelines for Financial Transactions. I am also the author of the book "Transfer Pricing Guidelines for Financial Transactions", published in 2021 by Wolters Kluwer.
Our firm offers clients a comprehensive and personalized approach tailored to their needs. Here are a few key elements that make our firm unique:
Our team consists of highly qualified tax experts with rich and diverse experience. We constantly update our knowledge in accordance with the latest regulations and changes in tax law, as well as the practice of tax authorities. Thanks to this, we can provide services at the highest level, providing clients with comprehensive and reliable advice.
We use the latest tools and software such as Bloomberg, Infocredit, TP Catalyst, and Royalty Range, which enable us to effectively manage knowledge and perform precise analyses. Thanks to such tools, we can respond to changing market conditions on an ongoing basis and update analyses in line with customer needs.
We are convinced that each client is unique and requires a personalized approach. That is why we carefully analyze the needs and goals of our clients to be able to offer them the best solutions tailored to their individual situation and industry specializations. We are tax experts with many years of experience in various industries, so we are convinced that we can effectively and efficiently support our clients in their activities.
Our law firm focuses on long-term relationships with clients, based on partnership and trust. We strive to fully understand the needs of our clients and are committed to their success, providing consulting services at the highest level.
All of these elements enable us to provide our clients with professional and comprehensive tax advisory services that deliver real benefits and support the growth of their business.
Below, we present a list of the most common mistakes in the area of transfer pricing that may result in inaccurate data being presented in the TPR information or transfer pricing documentation, as well as in the analyses conducted. As a consequence of these mistakes, a company may be exposed to challenges regarding the reliability of its documentation or the submission of TPR information that does not align with the actual situation, which could lead to penalties under the fiscal criminal code. By addressing these issues in our offering, we aim to demonstrate to our clients that we are fully aware of the most frequent challenges related to transfer pricing and are capable of providing comprehensive assistance in resolving them.
Receiving Gratuitous Guarantees from Related Parties. Our offering focuses on identifying and assessing the risks associated with gratuitous guarantees from related parties. We provide a comprehensive analysis of the client’s situation and offer advisory services regarding the determination of appropriate collateral and the potential settlement of these transactions in accordance with legal requirements.
Disproportionately High Service Costs in Relation to the Company’s Functional Profile. Our offering includes a review and optimization of the service cost structure in the context of the company’s functional profile. We focus on developing a target service structure that primarily reflects the business need for purchasing these services. We identify the types of services and propose strategies aimed at aligning these costs with the actual needs and operations of the company.
Lack of Trademark Valuation and Absence of Licensing Fees or Excessively High Fees Relative to the Company’s Profile. In our offering, we emphasize the importance of trademark valuation and the need for appropriate settlement of licensing fees. We provide services in the valuation of trademarks and in adjusting licensing fees to reflect their true value and the client's business profile.
Errors in Valuing Remuneration for Financing in the Form of Intra-group Loans. Our offering includes comprehensive advisory services in the valuation of remuneration for received or granted loans from related parties. We work to ensure compliance with legal requirements and optimize the financing structure to minimize the risk of errors or irregularities.
Restructurings, Acquisitions, or Mergers that Do Not Account for Remuneration to Related Parties. We offer assistance in the proper settlement of transfer pricing arising from restructurings.
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Izabela Wójcik
Director, Tax Advisor
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Paweł Turek
Partner, Attorney-at-law, Tax Advisor