Poland

Reviews

Practice area

World TP Reviews

Transfer pricing
Arena Tax

Joanna Deutyk is the transfer pricing director at Arena Tax in a team of 10 professionals and is well experienced in transfer pricing advisory. The TP team assists with identifying tax risks concerning existing methods and TP policy, and evaluation services for fixed intangible and tangible assets concerning tax, TP and business purposes. The team specialises in advising large and medium international firms in the financial, fintech and IT industries.

Baker & McKenzie Krzyżowski i Wspólnicy

Baker McKenzie's Warsaw TP team is part of the global TP group, which has more than 200 professionals. The Polish TP team of economists, attorneys, and tax advisers are experienced in assisting group companies regarding intragroup transactions, TP dispute and TP policy. Tomasz Chentosz, counsel, specialises in transfer pricing.

Crido Taxand

Crido Taxand’s transfer pricing team consists of more than 30 professionals. The firm has a portfolio of clients advised, including multinational entities in various industries such as Bridgestone, Costa Coffee, FUJIFILM, IBM and more. The transfer pricing department has contributed to post-BEPS challenges with the 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 in 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. Ewelina Stamblewska-Urbaniak, partner, leads the TP practice and works closely with Anna Wcisło, partner, also specialising in TP. 

The TP team advised a Polish energy group company on a $1.2 billion valued integration of its businesses. This involved identifying the business restructure in relation to the TP aspects, such as, if it’s aligned with the TP regulation, evaluation of the implication of the integrated business processes, valuation of the business restructuring remuneration, and encompassing the transfer of intangible assets from the integrated business processes.

Client feedback

“Very good, professional, quick response time and has broad experience from our sector.”

“High quality of work; experienced staff who are familiar with ongoing changes in the local TP law.”

“Very well organised and highly skilled.”

Deloitte

Iwona Georgijew, partner, leads the transfer pricing team at Deloitte Poland. The team has two partners and four directors focusing on TP advisory work. Mariusz Kazuch, former head of the National Revenue Administration APA and MAP teams, joined the firm in 2018. The transfer pricing team prides itself with achieving 100% effectiveness in defending clients on TP questioning, TP documentation and economic analysis and APA submissions, of which none has been rejected. 

The team advised one of the largest Polish energy groups with an APA for a long-term electricity contract valued at $1.6 billion. The task entailed designing a TP model consistent with the business model, application of the APA, negotiation with the tax authority and more.

Dentons

International law firm Dentons is highly recommended for its innovative tax practice and has a formidable transfer pricing practice actively assisting large MNEs and group companies. The TP team offers support with producing TP documentation, benchmark studies, TP studies, representation in TP disputes and more. The team is experienced in the energy, pharmaceutical, real estate, technology and telecommunications, infrastructure and finance industry. There are three partners advising in all tax matters; Cezary Przygodzki and Karina Furga-Dąbrowska co-head the practice.

Przygodzki led the team advising Fresenius Kabi on producing TP documentation and conducting benchmark analysis for numerous intragroup transactions for Polish subsidiaries of the global pharmaceutical group. The value of the transactions was estimated at $85 million.

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 Platform, Solutions & Intelligence and operational transfer pricing practice serving clients’ needs across all jurisdictions.

Led by well-recognised, Oslo-based partner Sveinung Baumann-Larsen, the operational transfer pricing team brings together multi-disciplinary experience and resources focusing on IT, accounting, and tax from the entire region to bring to bear 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.

Magnusson

Magnusson is recognised and recommended for tax legal advice. The tax team assists on all tax legal and compliance matters and offers transfer pricing advice. Tomasz Rysiak, partner, is experienced in assisting group companies with TP documentation work. The industries in which the firm specialises in are fintech, technology, retail, healthcare and real estate. Tax partner Tomasz Rysiak and Agnieszka Pytlas lead the practice.

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 is experienced in advising domestic and foreign groups in all transfer pricing areas such as TP studies, documentation, MAPs, APAs, TP audit dispute and more. It is especially experienced in industries such as retail, telecommunication, building materials, automotive, pharmaceuticals, IT and finance/insurance. The TP team is experienced in preparing maser files, local files aligned with the requirements in 13 countries, applying transfer pricing models into practice, redesigning main business practices, valuation of royalty fees and more. In addition, it assists in the negotiation for APA-approval from the tax authority. Magdalena Marciniak is the partner heading the TP practice and works closely with TP partner Renata Dłuska. 

Marciniak led the TP team assisting real estate group Globalworth Group with all TP matters in a £1.3 billion project. The team examined and determined the arm’s-length fee for both service and financing transactions between the individual entities in the real estate investment project, drafted contracts for the intra-group transactions settlement, prepared the TP policy clarifying the principles of settlements and more.

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 practice. The TP practice advises clients with identifying TP risks, identifying and analysing related-party transactions, risk management procedures for related-party transactions, TP documentation and more. Patrycja Balicka, counsel, specialises in transfer pricing. 

The team advised a media company with preparing TP documentation, including all its local transactions and cross-border transactions consistent with the new documentation standard. It included compulsory benchmark study of the client’s transactions.

Client feedback

“They are the best tax advisers and it was a pleasure to cooperate with them.”

“MVP Tax has met our expectations during our cooperation. I see MVP Tax as a trustful partner providing professional knowledge of TP law, and on existing and upcoming changes. The team was always available and sticks to the agreed deadlines. It's a pleasure to work with, and for a reasonable remuneration.”

“I rate MVP Tax 10 out of 10. Quick response and a very helpful team with wide tax knowledge.”

PwC

Piotr Wiewiórka, partner, specialises in transfer pricing. The tax team, headed by managing partner Jan Wacławek, has been active in Poland for more than 28 years, providing full tax and TP services to its multinational corporations and group holding companies. PwC Poland focuses on transfer pricing, indirect tax, international tax, litigation, dispute resolution, HR services, tax management and accounting, digitalisation of taxes and legal.

Wiewiórka led the team advising a real estate company on the TP aspects of its business restructuring and exit fee calculation. The value of the total assets associated in the restructuring was more than €200 million. The team developed a financial model to forecast future cash flows of the related entities effected by the restructuring, which supported the calculation of the exit fee.