Preparing transfer pricing documentation and submitting TPR forms are important obligations for taxpayers conducting transactions with related entities. This applies to both local documentation (local file) and group documentation (master file), as well as the obligation to provide information on transfer prices in the form of TPR-C or TPR-P forms. Our law firm provides comprehensive advice on transfer pricing – we support clients in preparing documentation, conducting market analyses of transactions, and liaising with tax authorities to reduce the risk of disputes and ensure compliance with regulations.
We provide legal and tax support at every stage of transfer pricing obligations, from transaction analysis to the preparation of complete documentation. We offer the preparation of local transfer pricing documentation (local file), comparative analyses, group documentation (master file), as well as the development and implementation of transfer pricing policies in capital groups.
We represent clients in proceedings before tax authorities and support them in their dealings with the National Tax Administration, including responding to requests and making corrections. We also assist in the correct completion and submission of TPR forms for a given tax year – both TPR-C and TPR-P. We operate on the basis of current regulations, individual interpretations, tax authority practices and applicable case law.
We have many years of experience in preparing transfer pricing documentation for domestic and foreign clients in a variety of industries, including IT services, manufacturing, trade, real estate, and the financial sector. We have carried out projects involving both simple purchase and sale transactions and more complex intangible services, intra-group restructuring and asset sharing. We have also handled transactions that required the use of non-standard transfer pricing analysis methods.
We have also assisted in preparing documentation for previous years, including in situations where the obligation to prepare such documentation was identified after the end of the tax year. We have experience in implementing transfer pricing policies within larger groups and ensure that the documentation complies with applicable international regulations and rules.
By entrusting the preparation of transfer pricing documentation to our law firm, entrepreneurs can be sure that all statutory obligations will be fulfilled in a timely manner and with due diligence. We offer advice that takes into account the specific nature of a given capital group and the nature of specific transactions with related entities.
Our approach is based on detailed analysis and precise tailoring of documentation to the taxpayer’s needs, taking into account market conditions. Working with us allows you to avoid potential financial penalties and the risk of tax authorities questioning your settlements. In addition, we provide support in the event of a transfer pricing audit or proceedings.
The obligation to prepare transfer pricing documentation applies to transactions or other events with related entities, provided that certain limits on revenue, costs, or transaction value are exceeded. The local file documentation should be prepared within 10 months of the end of the tax year, and the TPR form should be submitted by the end of the eleventh month.
In the case of related entities subject to the master file preparation obligation, it must be completed within 12 months. Failure to comply with these obligations may result in serious tax and fiscal penalties. Therefore, the documentation should be prepared not only formally, but above all substantively – based on reliable market analyses and knowledge of the business realities of the transactions.
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