• 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.

Tax Litigation Practice

The Tax Litigation Practice at MDDP provides comprehensive services to assist taxpayers in disputes with tax authorities, and also cooperates with the Litigation Practice at the MDDP Olkiewicz i Wspólnicy law firm in criminal, penal and fiscal and compensation proceedings conducted by this Practice, providing full legal assistance both to taxpayers as well as to persons against whom criminal or penal and fiscal proceedings are or may be pending and offering services in the field of compensation proceedings against the State Treasury.

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