Poland

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Transfer pricing
Arena Tax

Michal Musielak is the chairman of the tax advisory firm Arena Tax, which has 10 tax legal advisors, a total of 30 fee earners, including nine managers and directors. Joanna Deutyk is the transfer pricing director of a team of seven specialists and has comprehensive experience in transfer pricing, including working for a big four firm. The law firm covers all tax areas, but specialises in advising large and medium international firms in the financial, fintech and IT industries. 

The firm assisted with the transfer pricing methodology for payments for intragroup software services supplied by a local subsidiary, owned by an IT company. The team needed to amend the transfer pricing method because of the inaccuracy of the method applied in the past, which was based on the labour cost, which had increased dramatically and required adjustments.

Crido Taxand

Crido Taxand tax advisory consists of more than 120 fee earners. The firm has a portfolio advising multinational entities in various industries such as Bridgestone and Costa Coffee. The transfer pricing department has contributed to post-BEPS challenges by translation of the OECD/G20 BEPS project final reports on Action 8-10—Aligning Transfer Pricing Outcomes with Value Creation—which is new in the local market. The firm introduced a new transfer pricing terminology that is now being used the tax legal market and has developed IT solutions, such as online verifiers for transfer pricing requirements, providing feedback and information on new transfer pricing obligations from the financial details the client inputs.

The firm has advised an international group on redesigning a transfer pricing model for the royalty charges on a mixture of intangibles based on a profit-split mechanism. The royalties are a primary link to the activities of the group. The market value of the transaction was estimated at $120 million. The advisor carried out a functional analysis by developing a tailored DEMP matrix to determine the value created by the specific intangibles individually for each of the subsidiaries, acknowledging their different development stages and growth models.

Deloitte

Iwona Georgijew, partner, leads the transfer pricing team at Deloitte Poland. It has two partners including Georgijew and four directors. The experienced transfer pricing team offers full transfer pricing services to small and medium businesses in various industries. Its transfer pricing team combines technical solutions with its knowledge of the local circumstances and practices with the team’s 20-plus years of experience. 

Deloitte assisted a large, domestic company with designing a transfer pricing model for its intra-group financing valued at $1.9 Billion. The model needed to reflect BEPS developments regarding financial transactions and aligned to the Polish transfer pricing requirements implemented since 2017.

EY

The EMEIA Tax Center at EY is organised as a supranational entity covering the entire Europe, Middle East, India and Africa (EMEIA) region, with its Intercompany Effectiveness and operational transfer pricing practice serving clients’ needs across all jurisdictions.

Led by Oslo-based partner Sveinung Baumann-Larsen, it brings together multi-disciplinary experience and resources focused on IT, accounting, and tax from the entire region in its work. This work covers some of the leading global companies in their respective fields and includes those involved in retail and consumer products, energy and pharmaceuticals, to name but a few.

Michalik Dłuska Dziedzic & Partnerzy

Michalik Dłuska Dziedzic & Partners (MDDP) tax advisory firm has more than 80 tax professionals overall, with two partners and almost 30 advisors in the transfer pricing team. The firm has experience in advising small-to-large, and domestic-to-international entities in all tax advisory areas. It is especially experienced in industries such as retail, telecommunication, building materials, automotive, pharmaceuticals, IT and finance/insurance. It has experience in preparing maser files, local files aligned with the requirements in 13 countries, applying transfer pricing models into practice, redesigning of main business practices, the valuation of royalty fees and more. In addition, it assists in the negotiation for APA-approval from the tax authority.

The firm recently advised an international group in the real estate industry on setting up intra-financial structures. It involved determining the arm’s length remuneration for the whole intra-group, determining and setting the value for the guarantee fees for the guarantors for provision of the long-term net operating income and rental guarantee. The value of the deal was $1.2 billion.

MVP Tax

MVP Tax is a small boutique founded in 2016 by former big four and magic circle lawyers. Radosław Maćkowski, a former Deloitte employee, and Wojciech Pietrasiewicz, who has almost 15 years’ tax experience, lead the firm. They specialise in VAT, tax controversy, transfer pricing and R&D tax issues. They are building a specialised interest in sectors such as culture and entertainment, life sciences, real estate, media and advertising and consumer goods.

Pietrasiewicz led his team assisting a group entity on preparing transfer pricing documentation for a 2016 delineating all intra-transaction. It prepared documentation for both domestic and cross-border transactions, which included more than 20 transactions in total. It has also recently represented a client on a transfer pricing matter with a newly established customs-fiscal authority. The case involved transactions of tangled assets between related companies.

PwC

Jan Wacławek, managing partner, leads PwC’s tax and legal services. The team has been active in Poland for more than 28 years, providing tax advisory to multinational corporations and family business. There are more than 400 tax experts, including 124 certified tax advisors, with eight offices nationwide. PwC Poland focuses on transfer pricing, indirect tax, international tax, litigation, dispute resolution, HR services, tax management and accounting, digitalisation of taxes and legal. 

The team recently advised a real estate developer in designing a transfer pricing policy for interest rate setting. It involved producing a benchmark study for each of the approximate 400 intra-loan transactions between the related entities, and drawing a policy determining the arm’s length interest rates for future loan transactions.