Tax Litigation

• Preparation of transfer pricing documentation addressing the requirements arising from local tax regulations for all types of controlled transactions;
• Audit of transfer pricing documentation prepared by the Customer together with identification of irregularities and specification of tax risks;
• Preparation of Master File;
• Verification and adjustment of the so-called Master File to the needs and requirements of local tax regulations.

• Preparation of comparative analyses/transfer price analyses aimed at determining/verifying the market level of remuneration for various types of intra-group (service, goods, financial, license, rental, etc.) transactions;
• Verification of benchmarking analyses prepared by the Group / Customer with regard to transfer pricing regulations;
• Preparation of compliance descriptions for unusual transactions.

• Preparation or verification of a model of cooperation between related entities in order to submit an application for a decision of the Minister of Finance on an advance pricing agreement;
• Support in the preparation of an application for an advance pricing agreement and development of the necessary documentation;
• Support in negotiations and in the process of obtaining a decision of the Minister of Finance on an advance pricing agreement.

• Support in the preparation / verification of transfer pricing documentation for audit purposes;
• Support and representation during transfer pricing-related audits and litigation.

Smart.TP application:

• Automation of transfer pricing documentation held by the taxpayer for previous tax years;
• License for access to ready-made model transfer pricing documentation enabling independent generation of documentation for the most common types of intra-group transactions;
• Preparation of an individualized tool for independent generation of documentation (also for unusual transactions, configured at the Customer’s request);
• Archiving of prepared documentation and enabling the use of previous configurations for the purposes of preparing transfer pricing documentation for new transactions.

Smart.TP-R application:

• Facilitated compilation of mandatory information on transfer pricing, supporting the completion of the TP-R form;
• Verification of the transfer pricing risk regarding the taxpayer and transactions carried out with related entities;
• integration with the Smart.TP application – automatic completion of the TP-R form based on information included in the transfer pricing documentation;

• Support in the assessment and analysis of restructuring processes carried out between related entities;
• Valuation of exit payments of transfers made between related entities;
• Support in establishing the settlement methodology for planned intragroup transactions from the perspective of reducing TP risks;
• Development or verification of transfer pricing policy for planned or implemented intra-group settlements;
• Support and advice on transfer pricing adjustments.