Transfer pricing disputes and proceedings
The number of inspections of intra-group transactions by tax authorities is on the increase. Also, the taxpayers strive to safeguard against transfer pricing risks by applying for advance pricing arrangements. We represent Clients in proceedings before the Minister of Finance and tax authorities. Our services include in particular:
- representing Clients during inspections intended to check transactions with related parties.
- conducting the procedure of appeal against decisions of tax authorities before second-instance authorities and administrative courts,
- applying for advance pricing arrangements (APA) on behalf of Clients and representing them in the course of the proceedings.