Transfer pricing is an important topic in business operations. In cooperation with our clients, we analyze the company’s activities within the framework of capital relationships from the perspective of tax obligations. We prepare transfer pricing documents or check and improve the already existing documentation. We also offer assistance in developing long-term programs and plans related to settlements with related parties.
Transfer pricing – what is worth taking care of
We all agree that the most effective tool to protect against negative consequences of an audit is to prepare proper transfer pricing documentation. Many taxpayers are obliged to prepare such documentation. In addition to preparing the documentation, the TPR form should also be filed and the statutory deadlines should be kept in mind.
What does it mean that the documents are properly prepared
Unfortunately, we know from experience that not all transfer pricing documents, although prepared in due time, are considered correct. The legislator only defined the general framework as to the content that should be included in the documentation – however, no template for such letters was provided. In the rulings of administrative courts we read that they should be drawn up reliably and that they should fully reflect the course of the transaction. Therefore, we have no doubt that transfer pricing documentation protects the entrepreneur only when its quality and reliability are beyond reproach. If the tax authorities challenge a transaction, the mere fact of having the documentation is not enough for the entrepreneur to be sufficiently protected.