Transfer Pricing & Valuations

Our goal is to support your business as a whole. We provide a full range of transfer pricing and valuation services for entities based in Poland and groups of entities based in several countries. Thanks to this approach, our partners are provided with support in all fields where they operate and where transfer prices are part of the mandatory reporting.
We support fulfilling transfer pricing obligations, advise on policy making, assist in control.
We help to minimize tax risk related to transfer pricing from the perspective of the entire group and its value chains. We develop intra-group pricing policies based on the real business strategy of our partners. We prepare and coordinate global documentation that meets the requirements of each jurisdiction. Understanding your business and development plans is an essential part of our work.
Valuation techniques are recognised as a method of pricing between related and unrelated parties in many countries. Valuations are used not only for business and negotiation purposes, but also for tax purposes. We value both individual assets and entire companies. We use advanced database tools and modeling. Our advantage is the combination of knowledge in the field of valuations with business and tax knowledge so that our works can be applied for both business and tax purposes.

From the preparation of intra-group agreements to benchmarks and documentation necessary for audits and tax proceedings – every subject related to your settlements within capital groups is our priority. Our goal is to identify and secure potential risk areas while taking into account your business and financial objectives.

Based on our experience in economic analysis and financial modeling, we provide services of valuation of companies and fixed assets, including intangible assets.

Contact with a specialist:

Aneta Saramak

Aneta Saramak

Tax Managing Partner

Licensed Tax Advisor

Implemented projects:

  • Transfer pricing compliance

    We elaborate transfer pricing documentation files (Local Files, Master File) and benchmarking studies with prime objective to manage transfer pricing risk and document a uniform transfer pricing methodology of transactions between related entities.

  • Valuation of assets and liabilities

    We provide valuation services based on assed-based an income-based approaches (using for instance the discounted future cash flows method). Our analysts conduct valuation of assets and liabilities including fixed assets, enterprises, organized parts of enterprise, intangible assets (brand, know how, licenses, technologies, financial instruments) for the following purposes:

    • Tax (Art. 14 Par. 1 of CIT Act),
    • Transfer pricing (Business File),
    • Buy/Sell support (M&A),
    • Management decisions,
    • Business restructurings and exit taxation.
  • Transfer pricing policy

    Arena Tax specialists develop transfer pricing policies for international capital groups – such policy is aimed at simplifying the procedure of preparing transfer pricing documentation in various countries in accordance with Polish regulations and legal regulations of individual countries.

  • Intragroup agreements

    Our team develops and evaluates the agreements based on which the transactions between related parties are carried out.

  • Transfer pricing reviews

    Our team has experience in carrying out the following types of transfer pricing reviews: review of transactions in terms of TP regulations, reviews of transfer pricing documentation, reviews of existing intercompany relations (mapping), reviews of supporting documentation for TP purposes.

  • Advance pricing agreements

    We provide support in the process of obtaining an advance pricing agreements (APA).

  • Business files

    We identify arguments supporting the taxpayer’s position and prepare draft and final documents.

  • Preparation for transfer pricing controls and support in transfer pricing tax proceedings

    We prepare the documentation justifying the prices applied based on benchmarking analyses verifying market conditions of the transaction and the actual state of affairs. We provide assistance in completing and assembling the supporting documentation, as well as we represent the taxpayers during controls of tax authorities and in all the stages of tax disputes.

  • Exit tax

    We analyse and implement solutions which allow to calculate the base for exit taxation in various jurisdictions.