Tax documentation (Local File and Master File)
Entities entering into transactions with related entities or entities having their registered office or management in countries employing harmful tax competition are obliged to prepare tax documentation.
Tax documentation is one of the tools that enables the taxpayer to demonstrate that the terms and conditions of transactions with related parties are market-based and protect the entity against the application of the 50% punitive tax on the upwards-adjusted income.
This service is dedicated to those who do not have the capacity to organize their transfer pricing management units within their own organizational structures, or those who wish to prepare themselves for meeting the documentation obligation on the basis of model documents compiled by an advisory company.
The work aims to help the entity and its management to meet the documentation obligation and limit the risk for both the taxpayer and the persons responsible for the compilation of the above data.
THE TAX DOCUMENTS CONTAIN THE ELEMENTS INDICATED IN ART. 9A OF THE CORPORATE INCOME TAX LAW
- identification of the functions performed by the parties to the transaction,
- indication of the assets involved by the parties to the transaction,
- risk analysis of the parties to the transaction,
- identification of anticipated transaction-related costs, payment procedure and timeline,
- determination of the transaction object price,
- description of the method and manner of profit calculation,
- definition of the economic strategy and other factors, provided they affected the agreed transaction terms and conditions,
- determination of the expected intangible benefits acquisition.