About us

We are the first professional practice in Poland to specialize in transfer pricing.

 

Transfer pricing documentation and transfer pricing policy prepared by us is based on OECD so it can be used in many countries and companies to satisfy most of the requirements worldwide. 

Test if your company is obliged to prepare mandatory transfer pricing documentation for year 2018 or 2019:

The law gives taxpayers the right to choose which rules regarding documentation you wish to apply for year 2018:

  • either those obligatory for year 2018, or
  • those obligatory for year 2019

In many cases taxpayers will choose for year 2018 the new rules, because they are more favourable:

For 2019 the thresholds are increased to:

  • 10 mln PLN in case of goods (material goods) and financial services transactions
  •  2 mln PLN in case of services and other transactions

The domestic transaction is exempt from the documentation requirement if the parties do not have a tax loss and do not benefit from some tax reliefs (e.g.: special economic zones, support of investment).

For 2018 there were two thresholds:

  1. In regard to the entity : total earnings or total costs above 2 mln Euro in the preceding year
  2. In regard to the transactions: the gross value of the transaction above 50 000 Euro (or higher, if your earnings were higher) in the current year.

If you met both thresholds, there was obligation to prepare the local file.

Penalties

Since 2019 a penalty is introduced for reporting income (loss) outside the expected arm’s length amount. It is 10% on the adjustment made by the tax administration, or 20% if you do not have mandatory tax documentation, or 30% if the adjustment is above 15 mln PLN and there is no transfer pricing documentation.

In 2018 the penalty was only in case the tax payer did not present the transfer pricing documentation – a special increased rate of tax was applied to the adjusted amount – 50% instead of the regular 19%.

 

 

Our professional practice was started in 1992. We have experience in providing tax and management consulting services.

 

 

We optimize business structure and business transactions to minimize tax liabilities. We also provide security of running a business by adjusting business strategy to economic law, practice of tax authorities and case law.
We also advise our clients how to boost efficiency of business and how to improve company market value.
We also analyze the company's business position, analyze threats, look for opportunities, design business plans, design adequate business structures and prepare feasibility studies.

 

Please click on the right the “News” section  to find the most recent up-date on tax changes – changes in the law, or rulings or court judgements. If you have any further queries, please contact us. Short or general answers are free. 

 

We have professional experience in providing services for:

  • to Multi National Enterprises (MNE),
  • to local affiliate companies;
  • to act as power-of-attorney in tax investigations and court proceedings.

Our work is supervised by professional: Hanna Szarpak – licensed tax adviser

Hanna Szarpak – licensed tax adviser No. 446

hszLicensed tax adviser.
Expert on finance, experienced as a financial director in a large, multinational group (eight years) and a tax manager in PriceWaterhouse (three years).
Specializes in international taxes, transfer pricing, leasing and many other issues concerning tax and finance.

Experienced lecturer in renowned tax trainings for accountants and managers.

 

 


 

In the 90's adviser to the Minister of Finance on tax issues.
Experienced attorney in tax proceedings during tax investigations and in the Chief Administrative Court.

 

We have various specialized experts associated with our office.
With their cooperation we can take care of large projects in all areas of business.
References on request provided the client agrees.

 

Contact Us

mapa

Tax Advisory Company TCA Advisers Ltd

Registry Court No KRS 0000285612
NIP: 525-23-98-200
Regon: 140956595
ul. Stara 11/1
00-231 Warsaw

ul. Kościelna 20
05-510 Konstancin-Jeziorna

tel.: +48 502 405 439
e-mail: tca@tca.com.pl