In our practice, we encounter the issue of international cooperation almost every day, often carried out by entities belonging to the same capital group. CNKP cooperates with many entities operating globally. In addition to the legal aspects of such cooperation, special attention should also be paid to tax aspects related to so-called transfer pricing.
The awareness of our clients and the growing awareness of this issue by tax authorities means that more and more often transfer pricing issues are becoming the subject of jointly implemented projects. We cannot forget about the constant changes in regulations, including international regulations, concerning these issues.
We have completed many projects in this area together with our clients. We specialise in the preparation of transfer pricing documentation for our clients and conduct comprehensive projects related to this issue, from the initial and analytical phase, through the preparation of comparative data and documentation analyses, to the fulfilment of information obligations towards the tax administration. CNKP can assist you in, among others:
It is not an easy task to ensure that the conditions under which transactions are carried out between related parties comply with terms that would be agreed by independent parties. It is often necessary to contact a foreign tax adviser in order to jointly discuss the rules functioning in a given capital group. We have experience in cooperation with foreign partners in this area and we are familiar with international practice related to these issues. Taking into account the above, we are able to offer you high-quality, comprehensive services in this area.