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Transfer pricing documentation

Transfer pricing documentation

Preparation of mandatory documentation for transactions between related entities in accordance with Article 9a of the Polish CIT Act.

Preparation of mandatory documentation for transactions between related entities.

KPMG offers comprehensive support in preparation of the mandatory documentation for transactions concluded between related parties. We help in preparing new documentation required by Article 9a of the Polish Corporate Income Tax Act, as well as analyzing & updating the documentation prepared by the taxpayer.

Tax documentation according to regulations valid until the end of 2016

KPMG offers help in identifying economic events and transactions concluded by the taxpayer that require documenting in accordance with Article 9a of the Polish Corporate Income Tax Act. We help in preparing basic (primary) documentation, as well as documentation stemming from special provisions (documentation for low value adding services and business restructurings). Thanks to the cooperation with KPMG offices abroad we are able to verify the correctness and completeness of the documentation in the light of regulations set out by tax authorities in different countries.

Tax documentation according to regulations valid from 2017

On 9 October 2015, the Sejm adopted amendments to the Personal Income Tax Act, the Corporate Income Tax Act and certain other acts, as an answer to OECD’s Action Plan on BEPS (Base Erosion and Profit Shifting). As a result, a set of wholly new regulations related to tax documentation has been introduced. Taxpayers – upon fulfilling certain criteria – may be obliged to provide tax authorities with different types of documentation. KPMG offers help in verifying the taxpayer’s documentation obligations, as well as in preparing a comprehensive local file, master file and country-by-country reports. The scope of the new documentation is significantly wider than that required till 2016. KPMG will help get ready to the forthcoming changes and introduce appropriate documentation standards.

Defense file documentation – taxpayer’s supplementary protection

Transfer pricing audits are getting more and more effective. The Ministry of Finance has emphasized that intra-group settlements will be subject to a growing number of audits. KPMG helps in preparing supplementary documentation (defense file), which – alongside the transfer pricing documentation – constitutes a measure of protection for the taxpayer against tax authorities questioning the transaction’s arm’s length nature and assessing additional income. We offer support in identifying, collecting, sorting and organizing supporting documents and evidence that confirm realization of the transaction, as well as the validity of settlements.


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