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Support in tax audits and identification of risk areas
We provide comprehensive support in assessing the compliance of transfer pricing settlements with applicable regulations, as well as representing clients during tax audits and inspections. We assist in identifying and mitigating risk areas, reviewing documentation and processes, preparing required explanations and reports, and facilitating communications with tax authorities. Our objective is to protect the taxpayer’s interests, minimise potential adjustments, and ensure a higher level of tax security.
Our offer
Our support covers comprehensive activities aimed at ensuring that transfer prices comply with applicable tax regulations, and minimising transfer pricing risks:
- TP Review
We conduct a comprehensive review of current intra-group settlements from the perspective of compliance with local and international regulations. We focus on:
- reviewing and assessing the completeness of transfer pricing documentation (Local File, Master File),
- verifying transfer pricing methods and benchmarking analyses,
- verifying the accuracy of the process for identifying controlled transactions and the methodology for setting transfer prices,
- reviewing internal transfer pricing procedures, including evaluating their effectiveness and compliance with current tax regulations, and providing recommendations for improvements,
- auditing transfer pricing reporting (TPR forms), including verifying the accuracy and completeness of submitted returns, and assessing risks related to reporting incomplete or incorrect information,
- identifying potential tax risk areas and providing recommendations for remedial actions.
This process enables our clients to avoid sanctions and negative consequences arising from errors or gaps in fulfilling transfer pricing obligations, strengthens their position with tax authorities during audits, and optimises processes related to transfer pricing documentation.
- Support in Transfer Pricing Audits and Disputes
We provide comprehensive support throughout tax audits and proceedings related to transfer pricing. Our services include, among others, representing the client during tax audits or customs and fiscal inspections related to transfer pricing, analysing correspondence and requests from tax authorities, preparing responses, explanations, and supplementary documentation, assessing risks and defence strategies, supporting negotiations and communications with authorities, and preparing expert opinions or ad hoc reports.
We act both as a substantive advisor and a communication partner - helping to protect our client’s interests and to limit the impact of potential adjustments.
Tomasz Jankowski
A tax advisor specializing in transfer pricing and corporate income tax. Author of numerous tax commentaries and opinions published in industry publications and expert websites.