Magdalena Dymkowska


Transfer pricing

Mob.: +48 501 108 261

  • Transfer pricing expert.
  • Partner in a practice of over 50 people – one of the largest and most awarded transfer pricing practices on the Polish market.
  • She is responsible for the implementation of projects in the area of transfer pricing concerning, among other things: design of intragroup settlement models, preparation of comparative analyses and so-called compliance analyses for, among other things, manufacturing, distribution, services (including transactions related to the development of IT applications and systems), financial or licensing activities, as well as preparation of transfer pricing documentation.
  • She has experience in conducting projects regarding the analysis of restructuring processes in terms of their compliance with the transfer pricing rules, as well as defence of the arm’s length nature of intragroup settlements during tax audits.
  • She implemented projects regarding e.g. :
    • preparation of benchmarking analyses and compliance descriptions for several dozen transactions carried out by the Polish capital group operating in the telecommunications, energy and development industries;
    • verification of the existing and development of a new royalty settlement model (taking into account the DEMPE analysis combined with the profit sharing method) in one of the largest Polish capital groups;
    • verification and development of the financing model using, among others, cash pooling structures in one of the largest Polish capital groups;
    • developing TP’s policy on providing IT services and sharing the costs of IT system implementations for a large group operating in Europe.
  • She conducts trainings and workshops for clients on the application of transfer pricing regulations in practice.
  • Head of the working group of the Transfer Pricing Forum on the TP-R Informer under the Ministry of Finance.
  • 2009 Finance and Banking at the Warsaw School of Economics
  • Speaker at transfer pricing conferences and seminars
  • Languages: English
  • Highly regarded expert in Poland in the Transfer Pricing category in the World Transfer Pricing and World Transfer Pricing Leaders 2024,2023 and 2022 ranking published by International Tax Review
  • Partner at MDDP’s Transfer Pricing Practice awarded four times with the prize for the Best Advisory Firm in the field of Transfer Pricing in Poland granted by the International Tax Review (2006, 2008, 2012, 2013).
  • Member of MDDP’s Transfer Pricing Practice awarded in the ‘Innovations’ category in the Tax Advisory Firms Ranking by the Rzeczpospolita for an IT tool that speeds up and facilitates the process of preparing transfer pricing documentation (2018).
  • Author of publications on transfer pricing in daily and professional press