Planning and settlement of related party transactions

How to ensure tax certainty from a transfer pricing perspective?

Taxpayers are required to maintain the arm’s length nature of the consideration between related parties at the time of pricing transactions. In practice, this means having a transfer pricing analysis that confirms the market nature of the consideration in order to prove their case to the authorities and meet their tax obligations.

In addition, the development of high-quality transfer pricing analyses provides adequate security in the event of a potential dispute with the tax authorities.
Already in the planning phase of related-party transactions, it is worth considering the transfer pricing tax rules, especially in the context of preparing a transfer pricing analysis. Such an approach will ensure the marketability of the transaction from the moment it is implemented.

In addition, the analysis can also be a source of knowledge about

  • Competitors in the industry,
  • An examination of the financial position of comparable companies,
  • Potential collaborative partners.

How can we help you?

We prepare transfer pricing analyses (benchmarking/compliance analyses) which help to establish or verify the market level of remuneration for various types of intra-group transactions (services, goods, financial, licensing, other, etc.).

We also provide additional transfer pricing assistance, including the preparation of transfer pricing documentation, the preparation of transfer pricing policies, assistance in the proper handling of restructuring transactions from a transfer pricing perspective, or assistance during tax inspections.


Protect settlements against potential overstatement and allegations of non-market pricing by the tax authorities.

Zabezpieczenie rozliczeń przed potencjalnym doszacowaniem i zarzutem stosowania nierynkowych cen ze strony organów podatkowych.

Facilitate and expedite compliance with transfer pricing documentation and TP-R reporting requirements (automation).

Correct establishment of the accounting model, which will provide a solid basis for transfer pricing applied over several years.

Our experience

We have many years of experience in preparing transfer pricing documentation (local and master files) and transfer pricing analyses for Polish and international clients from the construction, energy, telecommunications, IT, real estate, food, automotive, transport, pharmaceutical, financial, leasing and other sectors.

We also focus on automating processes and saving our clients' time. Our SMART.TP and SMART.TPR applications make it much easier and faster to complete the documentation / TPR form, reducing the number of potential errors.

Please feel free to contact me

Magdalena Marciniak

Partner | Tax adviser | Head of the Transfer Pricing Practice