Transfer pricing

Taxpayers who perform transactions with related entities are required to ensure that these transactions comply with the arm’s length principle.

Our experts know how to address these requirements, allowing companies to focus on achieving business goals.

Our consulting is not only about transfer pricing documentation. ALTO’s support in the area of transfer pricing definitely goes beyond this area. We help entities operating in capital groups already at the stage of designing business models and implementing transactions, developing transfer pricing policies, preparing comparative analyzes and financial valuations, up to the development of adequate documentation. We offer complete support, tailored precisely to the company’s needs.

We support our clients on an ongoing basis in addressing more and more advanced requirements in the field of transfer pricing reporting. We develop local and group documentation, as well as transfer pricing analyzes for a wide range of transactions, including financial transactions, using professional databases.

In matters related to transfer pricing, we see not only obligations, but also opportunities to plan processes in a strategic and safe manner.

Range of services:

• Development of a transfer pricing policy.
• Preparation of transfer pricing documentation – local and group.
• Transfer pricing analyzes (benchmarks) for all types of transactions, including financial transaction analysis.
• Transfer pricing audits and risk analyzes in this regard.
• Conducting proceedings regarding advance pricing agreements (APA) and mutual communication (MAP).
• Representation in tax proceedings in the event of an audit.
• Support for transfer pricing adjustments (TP adjustment).
• Valuations for the needs of IP Box.
• Allocation of profit to the branch.
• Assistance in the preparation of declarations and forms necessary for tax purposes.