Local and group transfer pricing documentation

Local transfer pricing documentation

The obligation to prepare transfer pricing documentation is mandated by tax law to ensure that transactions between related parties adhere to market conditions.

An entity should also prepare transfer pricing documentation if it enters into a transaction with another entity with a domicile or place of management in a territory or country applying harmful tax competition (so-called tax havens) or a foreign permanent establishment located in a territory or country applying harmful tax competition.

Local transfer pricing documentation should be prepared if the value of the transaction during the tax period exceeds the thresholds indicated by the legislature.

Transfer pricing documentation must be prepared in accordance with current legislation.
Failure to comply with the obligation may result in high financial sanctions by the tax authority. At SWGK, we guide our clients through every step of the process, ensuring that the local transfer pricing documentation meets all legal requirements.

Professional preparation of documentation

Preparing the right documentation requires knowledge, accuracy and a personalised approach. At SWGK, we combine these elements to deliver the highest level of service:

An individual approach

We do not use schematic solutions, but tailor transfer pricing strategies directly to your company's needs.

Specialized knowledge

Our team comprises of experienced professionals who continually sharpen their expertise to deliver effective solutions.

Comprehensive documentation

We approach the preparation of transfer pricing documentation with the utmost care and accuracy. We handle every aspect of the process, ensuring that the documentation is complete and in line with current legislation.

Effective transfer pricing management

Our commitment extends beyond the preparation of documentation. We offer comprehensive advice to support you in determining the optimal transfer pricing strategy.

At SWGK, we prioritize innovation and precision in every aspect of our business. Our goal is not only to meet, but surpass our clients’ expectations by delivering tailored solutions that address their unique needs.

Support for group transfer pricing documentation preparation

The group transfer pricing documentation (master file) serves as a pivotal document for companies, outlining the transfer pricing principles and methods applied across the entire capital group.

The responsibility to maintain master file documentation falls on entities obliged to prepare local transfer pricing documentation within a group of related parties consolidated using the full or proportional method.
The preparation of transfer pricing documentation is also determined by the amount of consolidated revenues of PLN 200,000,000 or its equivalent.
Group transfer pricing documentation should include a description of the group, details of significant intangible assets, an analysis of key financial transactions and present relevant financial and tax information. Such documentation should be prepared by the end of the twelfth month after the end of the tax year.

As SWGK, we also support our clients in this respect by providing, among other things:

Consistent documentation:

We assist in the preparation of consistent and comprehensive documents that clearly present the transfer pricing policy across the group, facilitating understanding and verification by the tax authorities

Compliance with local requirements:

Our team supports clients in ensuring that group documentation complies with local regulations and jurisdictional requirements, mitigating tax risks and averting potential disputes.

We provide comprehensive assistance in the preparation of group documentation to protect you from unforeseen tax implications and potential penalties. With our wealth of experience and unwavering commitment, we serve as a reliable partner in this field.

Write us how together we can turn challenges into opportunities and we will prepare a tailor-made offer for you.