Transfer pricing

KSP Law Firm helps Clients man­age the risk con­nect­ed with the use of trans­fer pricing in trans­ac­tions with re­lat­ed en­ti­ties. In con­sul­ta­tion with our Client we iden­ti­fy trans­ac­tions that may give rise to tax risk in the ar­ea of sale of goods, fi­nanc­ing, in­tan­gi­ble ser­vices, li­cens­es re­ceived or grant­ed, as well as oth­er rights on in­tan­gi­ble as­sets.

We pro­vide a complete range of con­sult­ing ser­vices in the field of trans­fer pricing, in­clud­ing: 

• draw­ing up tax doc­u­ments for trans­ac­tions be­tween re­lat­ed en­ti­ties in com­pli­ance with tax laws;

• as­sis­tance in de­vel­op­ing the pro­ce­dures of on­go­ing man­age­ment of trans­fer pricing risk (adequate pricing policy);

• review of tax documentation made by the Client in terms of compliance with tax regulations – identification of tax risks and development of solutions which minimize the risks;

• ad­vice on allocation of income to per­ma­nent es­tab­lish­ment;

• rep­re­sent­ing clients dur­ing fis­cal or tax au­dits aimed to chal­lenge prices in in­tra-­group trans­ac­tions;

• benchmark study – preparation of a report on the level of intra-group prices and margins compared to terms of transactions between unrelated parties (verification of arm’s length settlements);

• transfer pricing policy within the group;

• work­shops on trans­fer pricing (prac­ti­cal lec­tures and class­es fol­lowed by an ex­am­i­na­tion if requested by the clien­t) for per­son­nel re­spon­si­ble for tax risk and prepa­ra­tion of tax doc­u­mentation.