Transfer Pricing

Fiscal Audit Protocol

About the Authors

Marcin Jakub Górski - Transfer Pricing Expert. His knowledge has been recognized by Polish Courts. Marcin is the first and the only one in Poland Sworn Court Expert Witness on the field of Transfer Pricing and benchmarking analyses. Marcin is experienced practitioner in the field of Transfer Pricing. He gained his professional experience working for the administration of western countries. During his career, Marcin dealt with Transfer Pricing issues also from the level of Ministry of Finance where he was responsible for auditing decisions of the Minister of Finance for Advance Pricing Agreements (APA). Marcin was a member of the Competence Centre for the Transfer Pricing and the base erosion and profit shifting - Tax Optimization, functioning within the framework of the Tax Audit Authority in Warsaw. He coordinated fiscal audits in the area of Transfer Pricing from the whole Poland. Trainer and lecturer in Transfer Pricing, whose knowledge, and experience in such areas as creation and revision of benchmarking study was used by the Centre for Education and Development of the Ministry of Finance, Tax Chambers and Fiscal Offices in the whole country. He trains both basic and advanced level practical application of the OECD Guidelines workshops as well as the national legislation in the field of Transfer Pricing. He was a participant in meetings with representatives of the European Tax Administrations, experts in the subject of Transfer Pricing and tax optimization. He was also a program participant in Economy & Society, Lancaster University and development programs created by the financier and founder of George Soros. Marcin is currently an adviser and consultant in the field of Transfer Pricing and tax optimization.

Adam Zbroiński - an experienced consultant, specializing in all procedures in the field of transfer pricing (audits, tax proceedings / control procedure APA). During his career he worked among other things, the Ministry of Finance (Department of advance pricing agreements APA), and Control Office in Warsaw (member of the Competence Centre for the transfer pricing and the shifting of income - tax optimization). He conducted training and workshops in the field of transfer pricing of, including within the Vocational Education Centre of Ministry of Finance. Participant of meetings with representatives of foreign tax administrations, a graduate of the Faculty of Law and Administration at the Nicolaus Copernicus University in Torun.