Transfer Pricing
Reduce tax risk by pricing your transactions correctly
You have the documentation. But do you have the arguments?
Our support does not end with preparing transfer pricing documentation. In the event of a tax audit or verification proceedings, we represent clients before the tax authorities, explain the solutions applied and defend the adopted arrangements.
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Transfer pricing comes with real responsibility. We help you manage it.
Transfer pricing documentation and TPR reporting are not merely corporate obligations. Their proper fulfilment ultimately depends on specific individuals who may face personal liability for missing documentation, reporting errors or information that does not reflect the actual facts and circumstances.
That is why our support covers the entire process: from identifying your obligations and preparing benchmarking analyses, through Local File and TPR reporting, to defending the adopted arrangements during a tax audit. We prepare documentation not only to meet formal requirements, but also to demonstrate the business rationale behind the transaction and support the arm’s length nature of the arrangements.
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We prepare documentation that not only meets the requirements, but helps defend your arrangements
Effective transfer pricing risk management requires you to act in advance. Where our analysis indicates that transaction terms deviate from arm’s length conditions, we help assess the situation, plan the appropriate course of action and mitigate risk before a potential tax audit. This gives management a clear understanding not only of the obligations that need to be met, but also of the risks involved and the arguments supporting the adopted arrangements.
A benchmarking analysis is the foundation for demonstrating the arm’s length nature of a transaction. We prepare it using specialised databases, carefully selected comparable companies and our experience in interpreting the results. Where transaction terms deviate from arm’s length conditions, we guide you through the necessary adjustments and reporting to ensure your arrangements are properly supported before a potential tax audit.
We don’t wait for questions. We proactively support your international growth.
We take responsibility for your security and success in a new market, not just for the tasks you assign to us. As a member of GGI Global Alliance, one of the world’s largest networks of independent advisory firms, we are there wherever you want to do business.
Build your Transfer Pricing strategy:
Transfer Pricing Obligations Assessment
Not every transaction with a related party triggers a documentation requirement. We analyse the structure and value of your transactions, identify your transfer pricing obligations and determine which areas require documentation or reporting.
Benchmarking Analysis
Arm’s length pricing needs to be demonstrated. We prepare benchmarking analyses using specialised databases, selecting the appropriate transfer pricing method and comparable data for each transaction. Our benchmarks are designed not only to meet formal requirements, but above all to support the arm’s length nature of your arrangements.
Local File
Transfer pricing documentation should explain the business rationale behind a transaction, not simply describe its terms. We prepare Local Files presenting the nature of the transaction, the pricing method applied and the arguments supporting its arm’s length character.
Master File
Local transactions are part of a broader group operating model. We prepare and support the preparation of Master File documentation, ensuring consistency between local arrangements and the structure, activities and transfer pricing policy of the wider group.
TPR Reporting
TPR is more than just another tax filing. We support the preparation and submission of TPR information, verifying that the reported data is consistent with the transfer pricing documentation, benchmarking analyses and the actual terms of the transactions.
Transfer Pricing Adjustments
Identifying that transaction terms deviate from arm’s length conditions is only the beginning. We analyse the feasibility and implications of transfer pricing adjustments and help plan the appropriate steps to mitigate tax risk and ensure consistency of future settlements.
Transfer Pricing Audits & Disputes
We prepare documentation with a potential tax audit in mind. We represent taxpayers during verification procedures and tax audits, explain the solutions adopted and defend the arm’s length nature of transactions between related parties.
Global support for ambitious international companies like yours.
NTAX is the only firm in the region offering global tax and accounting support to small and mid-sized businesses, delivering the service standards of the world’s leading advisory firms in an accessible and flexible model.
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How we work sets us apart
GLOBAL REACH
NTAX is the only Kraków-based firm that is a member of GGI Global Alliance, a prestigious global network of independent advisory firms. Gain access to our network of trusted partners across 130 countries worldwide. You choose the direction. We coordinate the rest.
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COMPREHENSIVE AND AGILE
We provide comprehensive tax, accounting and business advisory services without unnecessary bureaucracy. We deliver the standards of the world’s leading advisory firms while maintaining the speed and agility of a boutique firm.
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BUILT AROUND YOUR BUSINESS
We believe an advisor’s role goes beyond simply pointing out limitations. Our job is to find legally compliant solutions that enable you to achieve your business goals. We combine expert legal knowledge with a modern approach to management and strategic planning.
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