Transfer pricing has been a key priority for tax authorities for several years, with audits in this area becoming increasingly sophisticated and effective.
To select entities and identify areas of increased risk, the authorities use data from various sources, including transfer pricing reports (TPRs), Standard Audit Files for Tax and financial statements.
This means that taxpayers must maintain full data consistency, exercise greater care in their accounts and be prepared for detailed verification.
To discuss this further, we’d like to invite you to a webinar, where we will discuss key transfer pricing issues using examples of common transactions. We’ll also outline the main areas of risk and the current approach of the tax authorities, and suggest effective solutions and best practices.
Agenda
- Deadlines for fulfilling obligations for 2025: plan your schedule for working on this year’s documentation
- Are consortium members considered related parties? A brief overview of relations in practice
- Transactions of a similar nature – how to identify them correctly
- The most common related party transactions – typical challenges in light of practice and case law
Financial Transactions
- Setting documentation thresholds for selected financial transactions
- The circumstances in which the risk of reclassification as a loan becomes a reality
- Whether a free-of-charge suretyship between related parties can be considered to be at arm’s length
- The situation in which a full range does not guarantee security
Distribution Transactions
- How to correctly determine the functional profile of the parties to a transaction
- The crucial importance of FAR analysis
- Whether adjusting a distributor’s assumed margin is always a transfer pricing adjustment under Article 11e
Support Service Transactions
- The circumstances in which support services are actually low-value-added services
- Transfer pricing adjustments and their VAT implications – an analysis based on the Arcomet Towercranes and Stellantis Portugal cases
Transactions Involving Intangibles
- Licensing or low-value-added services – the risk of transactions involving intangibles being reclassified
- The DEMPE analysis – how to use it to determine the actual owner of the intangibles and how to apply it to determine the remuneration between related parties
Speakers
Wojciech Śliż, Tax Advisor, Partner, Tax Law
Katarzyna Pustułka-Wiater, Advocate, Associate, Tax Law
Who is this event for?
This event is aimed at CFOs and chief accountants of organisations that conduct transactions with related parties.
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Participation in the event is free of charge, subject to registration and application acceptance. The organiser reserves the right to select applications and also to cancel the event.
A link to the online broadcast will be sent to participants the day before the event.