Commercial Law, Labour Law, M&A, Civil Law

Economic Mediation and Arbitration, Court Proceedings, Legal Representation, Debt Collection

Restructuring, Bankruptcy, Compensation, Medical devices

Construction Law, Real Estate, Administrative and court-administrative proceedings

Competition protection, Personal rights of the entrepreneur, Protection of Personal Data

Accounting Outsourcing, Accounting Consulting and Corporate Services, HR and Payroll Outsourcing, Audit

Tax consultancy, Transfer pricing, Compliance Services, IP Box, R&D

Training - VAT, PIT and CIT as well as other legal and tax

Legal and financial and economic translations

Prawo Handlowe, Prawo Pracy, M&A, Prawo cywilne

Mediacja Gospodarcza i Arbitraż, Postępowania sądowe, Zastępstwo procesowe, Windykacja

Restrukturyzacja, Upadłość, Odszkodowania, Wyroby medyczne

Prawo Budowlane, Nieruchomości, Postępowanie administracyjne oraz sądowo administracyjne

Ochrona Konkurencji, Dobra osobiste przedsiębiorcy, Ochrona Danych Osobowych

Outsourcing księgowy, Doradztwo Księgowe i Corporate Services, Outsourcing kadrowo-płacowy, Audyt

Doradztwo podatkowe, Ceny transferowe, Compliance Services, IP Box, R&D

Szkolenia - VAT, PIT i CIT oraz inne prawno-podatkowe

Tłumaczenia prawnicze i finansowo-gospodarcze

Transfer prices

In our practice, we encounter the issue of international cooperation almost every day, often carried out by entities belonging to the same capital group. CNKP cooperates with many entities operating globally. In addition to the legal aspects of such cooperation, special attention should also be paid to tax aspects related to so-called transfer pricing.

The awareness of our clients and the growing awareness of this issue by tax authorities means that more and more often transfer pricing issues are becoming the subject of jointly implemented projects. We cannot forget about the constant changes in regulations, including international regulations, concerning these issues.

We have completed many projects in this area together with our clients. We specialise in the preparation of transfer pricing documentation for our clients and conduct comprehensive projects related to this issue, from the initial and analytical phase, through the preparation of comparative data and documentation analyses, to the fulfilment of information obligations towards the tax administration. CNKP can assist you in, among others:

  • preparation of a transfer pricing policy and preparation of tax documentation (the so-called local file and master file),
  • developing an analysis of comparative data, which is currently a mandatory component of almost every transfer pricing documentation;
  • preparation of information on transfer pricing that taxpayers provide to tax authorities as part of their reporting obligations;
  • representation in control proceedings regarding transfer pricing issues.

It is not an easy task to ensure that the conditions under which transactions are carried out between related parties comply with terms that would be agreed by independent parties. It is often necessary to contact a foreign tax adviser in order to jointly discuss the rules functioning in a given capital group. We have experience in cooperation with foreign partners in this area and we are familiar with international practice related to these issues. Taking into account the above, we are able to offer you high-quality, comprehensive services in this area.

Marcin Kowalski