Comprehensive tax advisory

Transfer pricing

Individuals responsible for tax settlements within capital groups / CFOs mention transfer pricing as one of the most important areas of tax risk and concern for their business operations.

At the same time, the impact of the progressing global economy recession and increasing market pressures result in capital groups seeking new ways to optimize effective tax rate, also through intercompany settlements. It results in more and more restrictive formal obligations in the area of transfer pricing.

In Enodo Advisors, we understand that transfer pricing aspects undoubtedly should be considered from a risk management perspective. For this reason, we offer support in preparation of obligatory transfer pricing documentation compliant with the Polish tax law (more...)

Our experience and transfer pricing services:

Tax optimisation Tax optimisation and planning using transactions between related entities
Transfer pricing policy Tax effective design and implementation of transfer pricing policies, including tax effective supply chain management.
Transfer pricing documentation Support in preparation of the transfer pricing documentation under the Polish law as well as so called localization of Group's Masterfile documentation for domestic purposes.
Transfer pricing analyses Preparation of transfer pricing analyses / benchmarking studies aimed at valuation or verification of the arm's length nature of intercompany charges.
Intra-group services Analysis of intra-group services (including costs allocation structures) and assistance in gathering and preparation of documentation supporting tax deductibility of service charges.
Restructuring operations Analysis and valuation of restructuring operations from the perspective of pre- and post-conversion issues, in particular potential taxation / financial burden resulting from the transfer of undisclosed intangibles / profit potential or other elements having an inbuilt economic "value".
Transactions regarding intangibles Assistance in planning, selection of methods and valuation of the arm's length charges with respect to intangibles.
Permanent Establishment Assistance in attribution of profits to PEs (permanent establishments).
Advanced pricing agreements (APAs) Support with respect to the application for Advanced Pricing Agreements (application design, negotiations with the authorities, etc.).

Transfer pricing issues are of international nature. Therefore, in the course of our work we take into consideration the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.

At the same time we take into account and analyse the current tax administration approach towards transfer pricing issues presented in Poland as well as in other countries, wherever the parties to cross-border intercompany transactions are located.

Our experience covers also active participation in the OECD's works regarding changes to TP Guidelines for Multinational Enterprises and Tax Administrations, as well as lectures during workshops and conferences on TP matters in Poland and abroad.