The obligation to prepare group documentation of transfer prices applies to companies obliged to prepare local documentation, which belong to capital groups preparing consolidated financial statements and whose consolidated revenues exceeded PLN 200 million in the previous tax year. Group documentation is one of the key elements of tax risk management in large enterprises operating in capital groups. It is a tool enabling the correct presentation of relations between related entities, as well as demonstrating compliance with applicable tax law regulations.
Modern regulations increasingly place emphasis on transparency and documentation of transactions in capital groups, which results from, among others, global actions to counteract base erosion and profit shifting (BEPS). In this context, the development of group transfer pricing documentation is becoming not only a legal requirement, but also a key element of effective tax and financial management of the entire group.
In response to the needs of enterprises, we offer comprehensive assistance in preparing group documentation of transfer prices. The scope of our service includes:
– understanding the organizational structure of a capital group is the foundation for developing group documentation. Our team conducts a detailed analysis of the functions, assets and risks of individual entities in the group, which allows for precise definition of their role in business processes. Establishing functional profiles is a key stage that provides information necessary for proper definition of the principles and methods of setting transfer prices.
– each capital group carries out a number of internal transactions, such as the provision of services, financial flows, asset transfers or the use of intellectual property. Our task is to thoroughly analyze these transactions in terms of their compliance with market principles and to identify potential tax risk areas. This allows clients to fully understand their obligations and make appropriate adjustments to their transfer pricing policies.
– the group transfer pricing documentation we prepare meets all the requirements resulting from Polish law and international guidelines, such as the OECD Guidelines. The preparation of this documentation includes, among others, a description of the group's activities, financial analysis and a comparison of the terms of the transactions carried out with the terms applicable on the market. We make sure that the documentation is not only compliant with formal requirements, but also transparent and easy to understand.
own regulations on transfer pricing, therefore adapting group documentation to local regulations is essential. In the case of Polish regulations, we take into account the specificity of the applicable regulations and formal requirements, such as the reporting structure or specific guidelines for consolidated financial data.
Working with us brings businesses a number of benefits, including:
Identification of areas with significant tax risk – carefully prepared group documentation of transfer prices allows for efficient identification of risky areas in terms of tax law. Thanks to the analyses carried out, clients can better understand their activities within the group and take appropriate steps to reduce tax risk.
Compliance with legal regulations – we ensure full compliance of group documentation with Polish transfer pricing regulations. In this way, companies can avoid potential legal consequences, such as financial penalties or additional tax burdens resulting from transfer pricing policies being questioned by tax authorities.
Support in tax audits – our documentation is prepared in a way that facilitates tax audits. In the event of a tax audit, it provides solid support, and we also offer assistance in representing clients before tax authorities. Thanks to this, companies can be sure that their interests are fully secured.
Preparation of group documentation of transfer prices is a process that requires knowledge, experience and familiarity with the specifics of legal regulations. With our help, companies can not only fulfill the obligations resulting from the regulations, but also effectively manage tax risk and increase their transparency on the market.
Please contact us – we will be happy to answer all your questions and propose solutions tailored to the needs of your capital group. With us, you can be sure that your group documentation will be comprehensive, compliant with regulations and fully resistant to verification by tax authorities.
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Izabela Wójcik
Director, Tax Advisor
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Paweł Turek
Partner, Attorney-at-law, Tax Advisor