Transfer pricing proceedings | KPMG | PL

Transfer pricing proceedings

Transfer pricing proceedings

Assistance in transfer pricing proceedings.

Assistance in transfer pricing proceedings.

KPMG provides advisory services in the area of preparation and conducting of negotiation procedures with tax authorities regarding transfer pricing agreements, including Advance Pricing Agreement (APA), Mutual Agreement of transfer pricing (MAP) and Arbitrage Convention. The purpose of concluding above-mentioned agreements is elimination of tax risks related to intercompany transactions or avoidance of double taxation.

Advance Pricing Agreement (APA)

KPMG supports its clients in conducting of proceedings with the tax authorities with regard to the conclusion of Advanced Pricing Agreements (APA). APA issued in the form of a decision of the Minister of Finance confirms an acceptance by the tax authority of the methodology for determining transaction prices (i.e. the method of calculation and the level of margins / prices) applied by the taxpayer in transactions with related parties. KPMG supports its clients in assessment of the validity and the chances of reaching an agreement, establishing an effective negotiating strategy, developing arguments in support of the proposed arrangements, and preparation of analyses essential in the negotiation process and during the application of the conditions of the agreement. In practice, as a result of conclusion of the agreement, the taxpayer benefits from elimination of the risks of questioning of pricing mechanism applied in a transaction between related parties.

Heading Mutual Agreement Procedure

Transfer pricing experts from KPMG provide support in conducting the mutual agreement procedures with tax administration in order to avoid double taxation according to Mutual Agreement Procedure. The services offered in this field include carrying out the procedure of reimbursement of double taxation. In addition, KPMG helps in making a transfer pricing adjustment in accordance with the principles set out in Arbitrage Convention. This service includes assistance during the procedure for the preparation of applications, representation before the authorities, the preparation of analyzes and monitoring the procedures.

 

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