• Preparation of transfer pricing documentation addressing the requirements resulting from local tax regulations for all types of transactions subject to inspection;
  • Audit of transfer pricing documentation prepared by the Client together with identification of irregularities and identification of tax risks;
  • Preparation of the Master File;
  • Verification and adjustment of the Master File to the ocal tax regulations
  • Preparation of benchmarking analyses / transfer pricing analyses aimed at determining / verifying the arm’s length level of remuneration for various types of intra-group transactions (service, goods, financial, license, rental transactions, etc.);
  • Verification of benchmarking analyses prepared by the Group / Client in terms of regulations regarding transfer pricing;
  • Preparation of compliance descriptions for unusual transactions.
#MORE about qualitative transfer pricing analyses >>
  • Preparation or verification of a model of cooperation between related entities in order to submit an application for an Advance Pricing Arrangement;
  • Support in the process of preparing an application for an Advance Pricing Arrangement and developing the necessary documentation;
  • Support in negotiations and in the process of obtaining an Advance Pricing Arrangement.
  • Support in the preparation / verification of transfer pricing documentation for tax audit purposes;
  • Support and representation during tax audit and proceedings regarding transfer pricing.

Smart.TP application:

  • Automation of transfer pricing documentation held by the taxpayer for previous tax years;
  • License for access to ready-made reference transfer pricing documentation enabling independent self-generation of documentation for the most common types of intra-group transactions;
  • Preparation of an individualized tool for self-generation of documentation (including documentation for unusual transactions, configured at the Cleint’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:

  • facilitating the compilation of mandatory transfer pricing information, supporting the completion of the TP-R form;
  • verifying the transfer pricing 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 for 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 the transfer pricing policy for planned or implemented intra-group settlements;
  • Support and advice on transfer pricing adjustments.
  • Support in the preparation of the application for initiating the Mutual Agreement Procedure in the case of double taxation, as well as support and representation in international administrative proceedings;
  • Advice on the possibility of using safe harbours for financial transactions and services with low added value;
  • Support in preparing the CIT-TP form for 2018 and TP-R form from 2019;
  • Development of methodologies / procedures / statements regarding the correct identification of relationships;
  • Support in analysing provisions regarding the risk of “non-recognizing” or “re-characterizing” of transactions;
  • Support with “Permanent establishment” from the perspective of transfer pricing.

MDDP’s Transfer Pricing Practice

MDDP’s Transfer Pricing Practice – comprised of around 50 specialists – is one of the largest practices in this field on the Polish market and one of the most awarded practices. The Practice received four times (in 2006, 2008, 2012, 2013) the International Tax Review award for the Best Advisory Firm in Transfer Pricing in Poland. Its leader – Magdalena Marciniak – was honoured in 2018 in the category of transfer prices as one of the best experts in Poland in the Tax Advisory Firms Ranking prepared by the Dziennik Gazeta Prawna. MDDP’s Transfer Pricing Practice was also honoured in 2018 in the “Innovations” category in the Rzeczpospolita Ranking of Tax Advisory Firms for an IT tool that speeds up and facilitates the process of preparing transfer pricing documentation.

The Practice offers unique solutions in a comprehensive way to meet the needs of clients belonging to international capital groups and making large-scale intra-group settlements, the purpose of which is to ensure their arm’s length nature and tax security. In implementing cross-border projects, MDDP cooperates with the Transfer Pricing Associates company based in Amsterdam, providing the highest quality services taking into account international aspects.

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