For many years we have been providing advice on significant and strategic transactions. It is not uncommon that these transactions are subject to transfer pricing regulations. We provide not only professional advisory services, but above all comprehensive, secure and customized solutions.

Our services include not only the preparation of tax documentation, but also transfer pricing risk management and planning of tax efficient transactions.

Our offer

Transfer pricing documentation

  • preparation of Local File
  • preparation of Master File (group documentation)
  • update of TP documentation
  • consulting in the preparation of TP reports


Benchmarking study


  • lease
  • management services
  • loans and guarantees
  • license
  • manufacturing
  • distribution of goods


Transfer pricing policy

  • preparation and implementation of transfer pricing policy
  • verification of transfer pricing policy already prepared


Fiscal and penal inspection

Assistance in:

  • fiscal inspections/audits
  • tax procedings
  • administrative court proceedings
  • penal-fiscal proceedings


Transfer pricing audit

  • verification of transfer pricing documentation
  • analysis of transactions carried out with related entities (in particular price analysis);
  • tax risks analysis and non-compliances identification
  • recommendations and guidelines preparation



  • partnership agreement drafting and consulting
  • verification of transfer pricing obligations
  • preparation of TP documentation



As part of the preparation of transfer pricing documentation and transaction planning between related entities, we have developed operating scheme that ensures that our tax documentation not only meets statutory requirements, but also guarantees you safety.


We become familiar with industry’s features and business you are conducting.


We become familiar with related-party capital structure and transactions performed.


We analyze the functions performed between related entities.


We determine arm's length price.


We present solutions and recommendations.

Selected projects

Examples of solutions that we have developed for our clients

Profit split in business partnership

Where business operations are highly integrated it is very important to properly determine the relevant profits to be split and profit splitting factors. We helped our client with the implementation of profit split method which is especially appropriate for transactions in which each party makes unique contributions (e.g. rights in intangibles).

Contract manufacturing

The contract manufacturer is responsible for making the custom-made product compliant with the specification given by customer. The question is what price should be set between related parties to keep it at arm’s length principle.

Loan interest

Determining the arm’s length interest rate on loans between related parties may be problematic. We have worked out a model thanks to which such transactions are safe.

Free guarantees and warranties

It is not uncommon that related entity provide free guarantee and warrantee. This transaction may be arm's-length transaction if you develop (and write down) the right economic strategy.

Real estate lease agreements 

Lease and tenancy are among the most popular agreements concluded between related parties. It is worth being aware that the obligation to have transfer pricing documentation may also apply to the company and its shareholders/partners.

Management fees

Management fees and service fees are closely scrutinized by tax administration. We offer complex solutions and prepare documentation which provides high level of security.