Linkedin
Facebook
Email
more
Contact our expert
Unsure whether your intercompany transactions within an MNE are accounted for correctly? To sidestep tax risks, review your company's transfer pricing policy. A transfer pricing audit and analysis of current and historical data conducted by RSM Poland tax advisors will ensure your organisation is fully compliant with its reporting obligations.
Why is it worth reaching for the support of RSM Poland when analysing intercompany transactions?
Our tax advisory team has extensive experience partnering with both local companies and MNEs and communicates fluently in Polish and English, allowing us to effectively support clients in diverse business environments. A thorough analysis of company documentation and the group's transfer pricing policy enables RSM Poland experts to precisely pinpoint potential risks and threats emerging from transactions between related parties, but that's not all. We also help you fulfil tax obligations that may have been overlooked (if the limitation period has not expired), thus safeguarding your company from costly tax implications. When carrying out transfer pricing audits, we:
- confirm the compliance of procedures in place – we check whether the scheme for accounting for transactions adopted by the related entity is aligned with the arm’s length principle as well as Polish law and confirm compliance with reporting obligations, so the organisation can be sure that in the event of a tax inspection the authorities won’t identify any documentation backlogs or nonconformities;
- highlight potential risk areas – we investigate all intragroup transactions and determine the level of tax risk associated with each;
- recommend specific solutions and corrective measures – we go far beyond analysis and – if tax risk areas are identified – we help make appropriate adjustments and propose actions that can be immediately implemented within the organisation.
Transfer pricing audit: step by step
1. Identifying transactions requiring transfer pricing documentation
When initiating a transfer pricing audit, we thoroughly analyse all related-party transactions the taxpayer performed during the last tax year (or during recent years for which transfer pricing reporting deadlines have passed but not yet become time-barred). We examine the transactions, comparing their terms with the open market using recognised transfer pricing verification methods, and determine those that, under Polish regulations, require transfer pricing documentation.
2. Assessing the existing transfer pricing documentation
Upon collecting a full list of reportable transactions, we conduct a comprehensive review of the transfer pricing documentation in place, evaluating the quality of the transfer pricing analyses (benchmarking or compliance analysis) and the alignment of the documents prepared by the entity with relevant law.
3. Checking for omitted or overdue reporting obligations
Towards the end of the review of the existing documentation, we verify whether the entity has met all required reporting obligations for the period under review. A comprehensive analysis covers the TPR-C/TPR-P forms and CBC-P/CBC-R obligations.
4. Presenting recommendations and corrective measures
Finally, based on the analysis outcomes, we offer detailed recommendations involving correct solutions and specific actions aimed at eliminating or mitigating the identified risks.
Frequently asked questions: What should you know about a transfer pricing audit?
A transfer pricing audit can cover a single tax year or the entire period of unexpired income tax liabilities – depending on the needs and expectations of the related party or MNE.
A transfer pricing audit is a service dedicated to companies that transact with related entities and want to examine their documentation obligations and confirm compliance with the arm’s length principle and their reporting obligations.
Auditing related party transaction documentation allows an organisation to point out potential tax risks, confirm the adherence of its transfer pricing policy to the arm’s length principle, and obtain recommendations for actions aimed at eliminating or mitigating identified tax risks.
The scope of a transfer pricing audit can be tailored to the individual needs of the organisation and expectations regarding the period and areas covered by it. Therefore, it can be conducted either comprehensively or on a case-by-case basis, covering the entire MNE or only a chosen entity operating in Poland.
Regular analysis of intragroup transactions enables you to steer clear of tax risks
Don't wait for a tax inspection – when conducting a transfer pricing audit, reach out to experienced tax advisors, ensuring that your organisation is well prepared for the review of the accuracy of related-party transactions and protected against lurking tax risks.
