Verification of transfer pricing obligations

Transfer pricing obligations

Compliance with transfer pricing obligations is an important aspect of a taxpayer’s tax responsibility, often drawing attention of tax authorities. To adhere to the formal and legal requirements stipulated by transfer pricing regulations under Polish law, a thorough verification of the taxpayer’s specific obligations is imperative. The identification of transfer pricing obligations inherent in the company is thus a fundamental step in fulfilling the transfer pricing requirements.

Verification process of transfer pricing obligations

As SWGK, we provide comprehensive support in identifying and verifying the taxpayer’s obligations under the transfer pricing regulations. Our services primarily include:

Identification of connections

At the first stage of the process of verifying the existence of transfer pricing obligations, we verify the company's links resulting from the regulations of the CIT or PIT Act. As part of this verification, we check what capital and personal connections the taxpayer has. In addition, we assist our clients in identifying family connections of persons performing key roles within the entity's business.

Determination of materiality of transactions and grouping

Once we have identified the links present in a given entity, we verify the transactions carried out by the taxpayer with related parties. First of all, we carry out operations to determine their materiality and group them in terms of homogeneity of transactions. The aim of our activities is to organise information on transactions with related parties, thus enabling the determination of transfer pricing obligations occurring in a given tax year.

Verification of documentation and TPR reporting obligations

After appropriate aggregation of data and identification of homogeneous transactions occurring, we verify whether the value of a given controlled transaction exceeds the documentation threshold, thus generating the obligation to prepare local transfer pricing documentation. As part of the services offered, we also verify the obligation to have group transfer pricing documentation and to prepare a TPR declaration.

Identification of obligations key to meeting transfer pricing obligations

The proper identification of controlled transactions conducted between related parties, along with the determination of the circle of related parties, is a key stage in fulfilling obligations under transfer pricing regulations. Our services provide holistic support in ensuring the proper implementation of the process for both identification and verification of documentation obligations.

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