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Transfer Pricing and Transfer Pricing Documentation


Our advice on transfer pricing and the related documentation is addressed to enterprises transacting with associated enterprises. Beneficiaries of our advice on transfer pricing and the related documentation are mostly international groups.

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 Rödl & Partner's transfer pricing advice includes (but is not limited to) the following services in Poland

  • tax reviews regarding transfer prices, including analysis of relations and terms of transactions between associated enterprises;
  • check of group contracts for compliance with tax regulations on transfer prices;
  • assistance in determination of the transfer pricing calculation method (the transfer price level), taking into account the business activity of the parties to the transactions;
  • comparative analyses (benchmarking);
  • tax assistance in verifying settlement rules concerning e.g. purchases of intangible services and tax treatment of the corresponding costs;
  • preparation, update or review of the obligatory documentation of transactions with associated enterprises, as required under Article 9a CIT Act and Article 25a PIT Act (transfer pricing documentation);
  • preparation, update and/or analysis of the comprehensive documentation covering low value-added services;
  • preparation, adaptation or analysis of transfer pricing policy;
  • assistance in restructuring the allocation of administrative resources among associated enterprises, including: preparation or analysis of cost allocation arrangements, assistance in determining the transfer pricing calculation method in the context of a specific model of administrative resources allocation, assistance in determining or verifying the transfer price level in order to ensure its compliance with the arm's length principle;
  • representation of associated enterprises in dealings with tax authorities, including without limitation: assistance in avoiding double taxation, preparation of applications for advance tax rulings, assistance in arguing about transfer prices;
  • preparation of tax opinions on transfer pricing issues;
  • training courses and workshops also in your company.


Outsourcing transfer pricing operations to professionals helps to manage an enterprise effectively thanks to appropriate planning, identification of risk areas and application of tools which help to minimise risks while taking into account business aims. This allows you to, among other things, avoid the risk that CIT and PIT amounts are subjected to a penalty tax rate of 50% which is imposed when an enterprise does not have the relevant documentation of transactions.

Rödl & Partner's interdisciplinary team of highly qualified specialists in transfer pricing is at your service. All our projects are tailored to meet individual needs and business assumptions. They reduce the risk relating to transfer prices and aim at optimising the tax burden. Our advisory services cover a broad range of issues and regulations laid down in both the national law and the international directives and guidelines.

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