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Defence file

It is a specialized document that provides additional justification for applying prices that deviate from market levels. Its purpose is to comprehensively substantiate the nature of a given transaction - even before a potential audit or during an ongoing audit.

What does a defence file look like?

The defence file we prepare is a tailor-made set of analyses and arguments, which may include:

  • comparative analyses (benchmarking) tailored to the specifics of the transaction;

  • expert commentary as well as additional calculations and supporting documents;

  • a detailed justification of the adopted approach, taking into account business and operational circumstances, the company’s current situation, and directions arising from its strategy.

Preparing such protective documentation is not mandatory, but it significantly strengthens the taxpayer’s position during an audit. It is a tool that allows the defensive argumentation to be developed in advance, enabling quick and substantive responses to allegations or questions raised by tax authorities.

Each document is created in close dialogue with the client and adapted to their structure and processes, ensuring both regulatory compliance and effective tax protection.

 

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Contact regarding the preparation of a defence file

Get in touch with us to learn more about the scope of our support and how we work on defence file projects.

Write us

or call: +48 61 855 30 10SHOW NUMBER

Check also

Other transfer pricing services: