Sep182025
Effective support in a customs and tax audit of an International shipbuilding company

Effective support in a customs and tax audit of an International shipbuilding company​

MDDP provided comprehensive advisory support to a prominent shipbuilding company during a customs and tax audit concerning its corporate income tax (CIT) settlement for the year 2020. The company, which had experienced losses, attracted the attention of the tax authority, which subsequently focused its investigation solely on transfer pricing matters.

The auditors raised questions regarding the losses incurred from the company’s main activity – selling machinery to its parent company in Denmark. In response, MDDP experts conducted an in-depth analysis, considering multiple factors including:

· The company’s financial structure of the company over the years,

· Transfer pricing documentation, both local and group-level,

  • The business strategy of both the Polish entity and its parent company,
  • Market conditions and investment timelines in the shipbuilding sector (notably, 2020 was among the company’s first operational years),
  • Extraordinary factors affecting 2020 market operations,
  • The company’s restructuring during the period, including the acquisition of a smaller entity and its impact on tax outcomes,
  • The shift in the company’s functional profile following the acquisition, which played a key role in the development strategy and subsequent financial and tax consequences.

MDDP’s experts presented a robust business argument to the tax authority, which incorporated these various elements while emphasising the international scope of the group’s activities. The analysis successfully demonstrated that the transfer pricing model applied by the company was market-based and well-justified, accounting for the observed deviations.

As a result of MDDP’s strategic support and comprehensive comparative analysis, the tax authority fully accepted the company’s arguments. The company was able to defend the arm’s length nature of its transactions, successfully avoiding an additional taxable income adjustment of approximately PLN 2.5 million.

The project was led by Magdalena Marciniak (TP), in collaboration with Marta Klepacz (TP).