Our offer contains a service of preparing tax documentation of transfer pricing, regarding transactions carried out with capital related entities, personally or familywise, and with countries that apply harmful tax competition, i.e. "tax havens".

The documentation prepared by MMB Kancelaria meets the requirements contained in the applicable provisions of the Corporate Income Tax Act and the Personal Income Tax Act.

The purpose for which transfer pricing tax documentation is prepared is to show that transactions carried out with related entities do not differ in price from those carried out on market conditions. If the entity owns this documentation, the burden of proof that the transaction deviates from market values ​​rests with the tax authority. Therefore, having logical, consistent and legal documentation makes it very easy for the taxpayer to defend himself. In addition, such documentation protects against the application of a 50% sanctioned tax rate on estimated income and the consequences of the Penal and Tax Code.

The deadline for preparing transfer pricing documentation is inevitably approaching. Taxpayers are required to prepare local documentation and comparative analyzes by April 2, 2018, and in the case of Master File documentation they should have it from the date of submitting the tax return (annual tax return) by the related entity that prepared the documentation for the group (including the taxpayer). This means that there is less and less time to prepare documentation in accordance with the new requirements.

Transfer pricing documentation