Global transfer pricing
Transfer pricing 360o
Our comprehensive global Transfer Pricing support
We provide companies with:
- comprehensive transfer pricing advisory services, ensuring compliance with local regulations,
- A seamless, end-to-end process that minimizes client involvement.
MDDP prepares all necessary documentation and, when needed, works with local advisors—for instance, in complex cases or during tax audits.
Setting a consistent Transfer Pricing policy:
- Defining and implementing a uniform transfer pricing policy for local transactions, if required.
- Developing or reviewing transfer pricing policies for intra-group settlements—at the group level or for individual entities.
- Auditing settlement models for existing or planned value chains and supporting risk mitigation.
- Designing cooperation models between related entities in line with OECD Guidelines and local regulations for all types of intra-group transactions.
- Providing support for intra-group reorganizations and restructurings, including M&A transactions and IP transfers.
- Assisting with the application of safe harbor simplifications.
- Determining arm’s length profit allocation to a permanent establishment (PE) from a transfer pricing perspective.
Ongoing support from MDDP and local advisors:
- Providing ongoing support from MDDP and coordinating with local advisors when needed.
- Assisting with tax audits and transfer pricing controls.
- Supporting the advance pricing agreement (APA) process.
- Facilitating the mutual agreement procedure (MAP)..
Contact with group or contractors:
- Facilitating communication with the Group or its contractors (e.g. accounting firms) to gather the necessary information for compliance.
- Ensuring seamless communication between companies and the Group on transfer pricing matters.
- Assisting with documentation and reporting obligations by verifying and adapting Group templates to comply with Polish transfer pricing regulations.
- Helping foreign management boards meet Polish transfer pricing requirements.
Preparation of a duty calendar:
- Preparing a calendar of obligations in each country – if required.
Identification of TP obligations:
- Assessing companies' documentation and reporting obligations.
- Assisting foreign management boards in meeting Polish compliance requirements.
Preparation of a Local File:
- Compiling a Local File, including jurisdiction-specific requirements, in accordance with local laws and OECD guidelines.
- Ensuring compliance by verifying and adapting Group-provided templates to Polish regulations..
Preparation of transfer pricing analyses (benchmark):
- Conducting transfer pricing analyses—where possible, jointly for all entities engaged in a given type of transaction—to meet jurisdictional requirements.
- Preparing high-quality transfer pricing analyses using professional databases (both international, e.g. TP Catalyst, Bloomberg, Royalty Range, and local, e.g. QTPA).
- Securing approval from local advisors on practical benchmarking requirements, including insights from tax audits..
Preparation of a Master File:
- Preparing a group-wide Master File in accordance with local regulations and OECD Guidelines.
Preparation and submission of TPR Form in Poland:
- Drafting and submitting the TPR form to the Polish tax authorities.
- Ensuring compliance with Polish regulations for companies obligated to submit the TPR form.
Preparation of additional Transfer Pricing reporting:
- Managing additional transfer pricing reporting, if required.
- Preparing information on group entities for the Country-by-Country Report (CbC-R).
Updating documentation annually or as required:
- Ensuring timely updates to transfer pricing documentation in compliance with legal requirements.
- Updating local files, master files, transfer pricing analyses, and other documentation annually or as per jurisdictional requirements.
Translation of transfer pricing documentation:
- Translating transfer pricing documentation into local languages, if required.
Internal procedures for Transfer Pricing risk mitigation:
- Developing internal transfer pricing procedures to mitigate risks for members of the management board.
Setting a consistent Transfer Pricing policy:
- Defining and implementing a uniform transfer pricing policy for local transactions, if required.
- Developing or reviewing transfer pricing policies for intra-group settlements—at the group level or for individual entities.
- Auditing settlement models for existing or planned value chains and supporting risk mitigation.
- Designing cooperation models between related entities in line with OECD Guidelines and local regulations for all types of intra-group transactions.
- Providing support for intra-group reorganizations and restructurings, including M&A transactions and IP transfers.
- Assisting with the application of safe harbor simplifications.
- Determining arm’s length profit allocation to a permanent establishment (PE) from a transfer pricing perspective.
Ongoing support from MDDP and local advisors:
- Providing ongoing support from MDDP and coordinating with local advisors when needed.
- Assisting with tax audits and transfer pricing controls.
- Supporting the advance pricing agreement (APA) process.
- Facilitating the mutual agreement procedure (MAP)..
Contact with group or contractors:
- Facilitating communication with the Group or its contractors (e.g. accounting firms) to gather the necessary information for compliance.
- Ensuring seamless communication between companies and the Group on transfer pricing matters.
- Assisting with documentation and reporting obligations by verifying and adapting Group templates to comply with Polish transfer pricing regulations.
- Helping foreign management boards meet Polish transfer pricing requirements.
Preparation of a duty calendar:
- Preparing a calendar of obligations in each country – if required.
Identification of TP obligations:
- Assessing companies' documentation and reporting obligations.
- Assisting foreign management boards in meeting Polish compliance requirements.
Preparation of a Local File:
- Compiling a Local File, including jurisdiction-specific requirements, in accordance with local laws and OECD guidelines.
- Ensuring compliance by verifying and adapting Group-provided templates to Polish regulations..
Preparation of transfer pricing analyses (benchmark):
- Conducting transfer pricing analyses—where possible, jointly for all entities engaged in a given type of transaction—to meet jurisdictional requirements.
- Preparing high-quality transfer pricing analyses using professional databases (both international, e.g. TP Catalyst, Bloomberg, Royalty Range, and local, e.g. QTPA).
- Securing approval from local advisors on practical benchmarking requirements, including insights from tax audits..
Preparation of a Master File:
- Preparing a group-wide Master File in accordance with local regulations and OECD Guidelines.
Preparation and submission of TPR Form in Poland:
- Drafting and submitting the TPR form to the Polish tax authorities.
- Ensuring compliance with Polish regulations for companies obligated to submit the TPR form.
Preparation of additional Transfer Pricing reporting:
- Managing additional transfer pricing reporting, if required.
- Preparing information on group entities for the Country-by-Country Report (CbC-R).
Updating documentation annually or as required:
- Ensuring timely updates to transfer pricing documentation in compliance with legal requirements.
- Updating local files, master files, transfer pricing analyses, and other documentation annually or as per jurisdictional requirements.
Translation of transfer pricing documentation:
- Translating transfer pricing documentation into local languages, if required.
Internal procedures for Transfer Pricing risk mitigation:
- Developing internal transfer pricing procedures to mitigate risks for members of the management board.
More about our Transfer Pricing team
What makes us the perfect match?
Since 2004, we have established a proven track record in delivering transfer pricing documentation, conducting benchmarking analyses, and securing advance pricing agreements (APAs). We are dedicated to providing comprehensive support during tax audits, addressing client inquiries and concerns with a personalized approach.
Our streamlined process ensures efficiency, enabling us to deliver high-quality benchmarking analysis within just one week. Our commitment to accuracy is reflected in the fact that none of our documentation or benchmarks have ever been contested on formal grounds.
We prioritize automation and efficiency, demonstrated by our SMART.TP and SMART.TP-R applications, which optimize the documentation process, minimize errors, and accelerate compliance.
Nearly 50 specialists
5
Partners
Responsible for project quality and client relationships
7
Senior Managers / Managers
Overseeing the successful implementation of projects
Expert Analysts and Consultants
Providing thorough research and documentation
For more details, visit our dedicated Transfer Pricing page: MDDP Transfer Pricing
Let us know your needs
Get in touch with us if you have any questions
Magdalena Marciniak
Partner | Tax adviser | Head of the Transfer Pricing Practice E: magdalena.marciniak@mddp.pl T: (+48) 665 746 360