Identifying the links between parties to a transaction is not only crucial, but also one of the first things a taxpayer should do before proceeding with transfer pricing documentation and reporting obligations. Given the high volatility and uncertainty of the tax laws, it is worthwhile to verify well in advance that for a given year…
Safe harbour is a mechanism to reduce documentation and transfer pricing reporting obligations provided that the taxpayer meets several statutory requirements. Once such conditions are met, the taxpayer is supposed to gain certainty as to the arm’s length nature of the price applied in the transaction carried out. However, is compliance with the conditions sufficient…
Group documentation is treated a bit lightly by taxpayers. After the hassle of preparing Local File with transfer pricing analyses and properly completing and submitting the TP-R form, many taxpayers would like to take a breather from transfer pricing obligations. However, we would like to remind you that for some taxpayers, group documentation is just…
In today’s dynamic business environment, organizations face constant challenges to remain efficient and competitive. In this context, one of the key aspects that often consumes a lot of time and resources is the preparation of various documents, such as financial records, reports, commercial offers, reports or tax documentation. The process of creating such documents requires…
The methods used to verify the transfer price are indicated in Article 11d of the CIT Act, i.e.: the comparable uncontrolled price method, resale prices, cost-plus, net transaction margin, profit sharing. However, taxpayers are not obliged to use only the above-mentioned methods when verifying transfer pricing. If it is not possible to apply any of…
The primary purpose of a benchmarking analysis is to establish and verify that the terms and conditions in transactions between related parties correspond to the arm’s length principle. Although only one of the integral elements of transfer pricing documentation, these analyses are crucial for taxpayers to meet their transfer pricing obligations. Unfortunately, taxpayers usually realize…
Identifying the links between the parties to a transaction is one of the first and at the same time the most important steps in the process of identifying transfer pricing obligations. Correct determination of linkages is particularly important if the parties to the transaction wish to take advantage of the exemption from the obligation to…
The economic situation in the global markets as well as the increase of banking reference rates, higher inflation rate could influence the conditions of intragroup financial transactions.
A consortium is a collaboration of at least two businesses to achieve a predetermined goal or to carry out a specific project for mutual benefits.
Remuneration in transactions between related parties should be determined on an arm’s-length basis: on such terms as third parties would determine between themselves. Otherwise, in the event of an audit, their arm’s length nature is expected to be challenged.