Transfer Pricing

Practices / Tax

Kochanski & Partners’ tax team has extensive experience in transfer pricing covering not only the preparation of transfer pricing documentation and benchmarking studies, but also economic analyses used for the purposes of court and arbitration proceedings.

With our experienced team of lawyers, tax advisors and analysts, we provide our Clients with comprehensive business solutions of the highest quality.

Our specialists have considerable experience in advising international groups, particularly those whose parent companies are based in the United States, Japan, the UK, Germany, Austria, the Netherlands, France, Spain, Portugal, Italy or the CEE region.

We have extensive experience in documenting transactions such as

  • Sales and purchase of goods, products and semi-finished products
  • Management, consulting, accounting and legal services
  • Intra-group loans
  • Trademark licensing
  • Technology transfer
  • FX Spot and FX Forward contracts
  • Mobile marketing services
  • Low value-added services

We offer services in the following areas:

  • Transfer pricing reporting
    • Preparation of the Local File
    • Preparation of the Master File
    • Making benchmarking studies
    • Preparing descriptions of compliance with the arm’s length principle
    • Support in the completion of TPR forms
    • Support in drafting the statement on transfer pricing documentation and application of arm’s length transfer prices
  • Transfer pricing risk mitigation
    • Identification of risk areas
    • Risk-oriented review of documentation, benchmarking and procedures as well as transaction agreements
    • Support in risk management
    • Advance Pricing Agreements (APA)
    • Mutual agreement procedures (MAP)
  • Transfer pricing audits and disputes
    • Support in tax audits and litigation concerning transfer pricing
    • Preparation of economic and business analyses for the purposes of court and arbitration proceedings
  • Planning transactions with related parties
    • Development of transfer pricing policies
    • Advice on special economic zones (including determination of the result obtained within the zone)