Transfer pricing

Transactions between related parties

All transactions between related parties (for example, between a company and its shareholder, or between companies with a common shareholder) should be conducted at arm's length.

This is particularly important in the case of international transactions involving entities from different countries, as such transactions attract particular attention from Polish tax offices.

Entities that generate small (or very large) revenues from services provided to affiliates based abroad, or that make very large payments for intangible services (including, for example, the right to use trademarks such as logos or the entity's name), are particularly scrutinised.

Transfer pricing documentation

In some cases there is also an obligation to prepare so-called transfer pricing documentation, which will confirm on the basis of independent data that the value of the transactions carried out has not been artificially inflated or understated.

The result of the analyses carried out should be reported to the tax office each year. Failure to comply with this obligation may result not only in consequences for failure to submit the relevant tax returns, but also in the office determining additional income tax to be paid on the disputed transactions.

Our services

If you carry out transactions with related parties (e.g. subsidiaries operating in Poland), if you have any doubts about your transfer pricing obligations or if you need assistance in comprehensively dealing with formal issues - do not hesitate to contact us.