Main responsibilities:• Country-by-Country reporting and Notification process coordination in CEE region.• Identifying, documenting and periodically reviewing related party transactions: preparing Master File, local transfer pricing documentation (Local Files) and CIT TP form. • Preparing of benchmarking studies (internal comparison analyses, external comparison analyses based on Bloomberg) and act as liaison with the external advisors for studies they prepare (including verification results of their works).• Advise the business on the transfer pricing implications of new inter-company transaction flows and business reorganizations.• Liaise with the lines of business, back office departments and controlling to provide input for further intercompany settlements.• Providing input to and reviewing intercompany agreements.• Identify and recommend appropriate action in areas of responsibility to mitigate the transfer pricing risk in light of the increasingly diverse and challenging commercial, regulatory and tax environment• Collaborate with local and foreign external advisors on planning and transfer pricing compliance matters • Development of transfer pricing policy including transactions related to goods, services (including financial services).

Transfer pricing documentation under applicable TP regulations and as of 2017: preparing and verifying whether TP documentation (master file, local file) is in line with local or selected foreign countries TP regulations, delegation and executing, meeting and calls with clients, gathering information necessary to prepare proper quality documents in Polish and English. Defense files – identification of arguments supporting taxpayer position, preparation of draft and final documents.External and internal benchmarking analyses: conducting and verifying transfer pricing analyses (local and pan-European) prepared based on the following databases: Amadeus, RoyaltyStat, LoanConnector and other alternative sources of financial data. Projects including analyses of profitability of entities comparable to main activities of tested party such as: contract manufacturing, contract R&D manufacturing, limited risk distribution, agent activities, distribution, provision of services (management services, marketing, IT, HR, legal, technical support, management of private equity fund, etc.). Financial analyses including verification whether remuneration for given loans and guarantees are arm’s length.Adjustments – preparation of adjustments as part of benchmarking analysis in order to including in results of the analyses potential differences in functional profiles of comparable from the final set and tested party.Substance analysis regarding marketing activities within the group of entities applying centralized provision of marketing services.

International trade activities: searching for relatively hard available products or in relatively competitive prices and offer them to clients located in Asia, Australia, Europe, North, Middle and South America, arrangement of payments, fulfilment of custom duties, preparing of ECS communication, connect buyers and sellers (foreign companies interested in investments in Poland and Polish companies interested in investments abroad and finding business partners), support in finding virtual office in Poland and Germany, support in expanding business in Germany (support in finding notary, bank and bookkeeping company, etc.).Alternative investments: Investment plan still in progress – alternative method of investment aiming at generating return on invested capital of 15%-20% annually.Selling credit facilities offered by bank to individual clients, entrepreneurs and companies.

Transfer pricing documentation under applicable TP regulations: preparing and verifying whether TP documentation is in line with local or selected foreign countries TP regulations, delegation and executing, meeting and calls with clients, gathering information necessary to prepare proper quality documents in Polish and English. Verifying and evidencing information and data that may be used as proofs of intra-group services transactions, preparing of procedure for gathering proper quality of evidences.External and internal benchmarking analyses: conducting and verifying transfer pricing analyses (local and pan-European), preparation of reports and participation in other projects aiming at verifying whether prices are arm’s length. Conducting analyses based on the following databases: Amadeus, Tegiel, RoyaltyStat and other alternative sources of financial data. Projects including analyses of profitability of entities comparable to main activities of tested party such as: contract manufacturing, contract R&D manufacturing, limited risk distribution, agent activities, distribution, provision of services (management services, marketing, IT, HR, legal, technical support, management of private equity fund, etc.). Financial analyses including verification whether remuneration for given loans and guarantees are arm’s length.Adjustments – preparation of adjustments as part of benchmarking analysis in order to including in results of the analyses potential differences in functional profiles of comparable from the final set and tested party.Advanced Pricing Agreements – preparation of initial files and replies on Ministry of Finance requirements regarding filling in of additional information.Exit fee analyses and calculation.