Advisory Services for the Preparation of Transfer Pricing Documentation

Our firm provides tax advisory services in the area of transfer pricing, preparing both local and group transfer pricing documentation in accordance with the requirements set out in the Corporate Income Tax Act, the Personal Income Tax Act, and applicable regulations. We also ensure proper reporting of transactions on TPR-C and TPR-P forms.

When preparing transfer pricing documentation, our team thoroughly analyzes transactions conducted by clients that require documentation and reporting to tax authorities—covering both transactions with related entities and those involving parties located in jurisdictions practicing harmful tax competition.

At the same time, we examine the prerequisites that may allow our clients to benefit from exemptions from documentation requirements or simplify the preparation process.

Particularly appealing to our clients is the application of provisions enabling the waiver of the obligation to prepare benchmarking and compliance analyses. Drawing on the provisions of tax laws and the Entrepreneurs’ Law, our experts assess clients’ financial and staffing data to determine whether they qualify as micro or small enterprises for a given tax year.

Thanks to these analyses, it has often been possible to simplify the structure of transfer pricing documentation, significantly reducing the required workload and preparation costs.

By cooperating with our firm, clients can:

• Eliminate potential risks associated with improper transfer pricing documentation,
• Gain confidence in the reported transactions and their values,
• Take advantage of regulatory simplifications, reducing costs and minimizing the involvement of their internal staff.

Tax advisory support in the area of transfer pricing is our specialty, and thanks to our extensive experience, we can deliver effective solutions.