Modern capital groups operate in an increasingly complex regulatory and market environment, which requires high transparency in internal clearing. Transactions between related parties, covering both financial flows and the exchange of goods, services or intangible assets, are one of the key interests of tax authorities, auditors and supervisory authorities.
Transfer prices, i.e. conditions set in intragroup transactions, must reflect market realities in line with the arm’s length principle. Their misconception, whether inadvertently due to the lack of appropriate procedures or intentionally, may lead to substantial accounting irregularities, tax disputes and, in extreme cases, to criminal or criminal-tax liability of board members and other persons responsible for supervising the compliance of operations.
From the point of view of risk analysis, intragroup transactions may constitute a space for:
- transfer of profits between tax jurisdictions (including tax havens),
- covering operational losses,
- financing of undocumented actions,
- circumventing regulatory or contractual restrictions,
- transforming the balance sheet structure in a way that can mislead stakeholders (e.g. banks, investors, regulators).
Therefore, a comprehensive diagnosis of transfer pricing policies and mechanisms for financial flows within the group is a key element:
compliance audits,
Internal investigations
preparatory or investigative proceedings,
preparing the organisation for tax control,
safeguarding ownership and management interests in M&A processes or reorganisations.
We offer support in identifying and analysing potential risk areas in capital group structures – from reviewing transfer pricing documentation and verifying compliance with the applicable rules, to analytical and investigative activities aimed at detecting fraud, irregularities and hidden value transfer mechanisms.
Our approach combines the legal, tax, financial and investigative perspective, allowing for comprehensive protection of the interests of the Client – both in preventive terms and in response to incidents or suspicions of irregularities.
Contact us to find out how we can help your organization become more resilient and aware of threats!