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TP Support in Restructurings and M&A Transactions
Restructurings and M&A transactions require a precise approach to transfer pricing as well as effective management of tax risk. Our support covers the entire process - from analysing and assessing the tax implications of planned changes, through reviewing and preparing the required documentation, to aligning the transfer pricing policy and intra-group agreements with the new operational reality. As a result, our clients can be confident that implemented reorganisations, business model changes, or M&A transactions comply with applicable regulations and are tax secure, whilst the adopted solutions remain consistent with the overall group policy.
Our offer
Our advisory services include:
- Restructuring Compass
We provide comprehensive advisory services for planning and implementing changes to the group structure. We assist in analysing the transfer of functions, risks, and assets, ensuring that the entire process observes transfer pricing regulations.
- Assessment of business model changes
We assess the impact of changes to the business model or the functional structure of the group on tax obligations and compliance with transfer pricing regulations.
- Valuation and support
We provide support in the valuation of transferred assets, functions and business activities between related parties, in accordance with the arm’s length principle and applicable tax regulations.
- Calculation of exit fee
We conduct a comprehensive assessment of the justification for applying a so-called exit fee in connection with the transfer of functions, risks or assets between related parties, and prepare the required documentation in line with tax regulations.
- Adjustment of transfer pricing policy
We conduct reviews and assist in adjusting the TP policy following structural changes, ensuring compliance with applicable regulations and consistency within the group.
- Update of intragroup agreements
We review, update and adapt agreements concluded between related parties to organisational and operational changes, as well as to the applicable transfer pricing policy.
- Monitoring of changes
We assess whether the implemented organisational and operational changes are carried out in accordance with the adopted TP model, and identify any deviations in the following years.
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.