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Transfer Pricing Guide

The revolution in the transfer pricing world has been continuing for many years. The BEPS works initiated by the OECD,to develop common rules to protect the tax systems of OECD member countriesare gradually implemented in many jurisdictions in Europe. The high scrutiny of the tax authorities is still focused on transfer prices, and the number of tax audits of related parties are focused on transfer pricing aspects.

For many companies amendments to local transfer pricing regulations mean a huge challenge resulting in practice in the introduction of significant changes to transfer pricing policy regulating the intercompany transactions. These changes apply to both the subjective scope - the list of entities that are subject to the documentation obligations, and the objective scope – the scope of the documentation has been broadened considerably. Taxpayers are required to provide tax authorities with much more detailed information, which involves increased administrative effort from compliance perspective and the need to develop specialized knowledge of transfer pricing concepts.

To help our clients - especially those who conduct business operations within multinational capital groups – prepare for these transfer pricing changes, we have prepared our second edition of "Transfer Pricing Guide" (legal status obliging on 21/09/2018), which has been created in collaboration with the leading European advisory companies. We have focused on jurisdictions which are located mainly in Central and Eastern Europe and have gathered not only the most important information on the transfer pricing law effective in a given jurisdiction, but also a set of practical information that many of you may find useful while struggling with the new challenges during preparation of transfer pricing documentation.

We hope that the guide will be useful to you. Should you have any questions regarding its contents or other issues related to transfer pricing, please contact us.


Renata Dłuska, partner                 

Magdalena Marciniak, Head of Transfer Pricing Group  


If you are interested in downloading the "Transfer Pricing Guide", please fill in the form and the material will be sent to your e-mail address:






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