The situation
The group’s intercompany agreements and a list of flows by entity and value
A manufacturing group has a shared-service centre in Kraków, a plant in Ostrava and a distributor in Žilina. The SSC charges accounting and IT to both sister companies, the plant sells to the distributor, and the parent lends money to all three. The group’s tax manager asks your firm what documentation each company must prepare this year.
Each country starts from the same OECD structure and sets its own rules on top. The time goes on matching each flow against each country’s thresholds and categories, finding which filings go with the documentation and when, and keeping it all in one outline the client’s team can work from.
What the research has to settle
The rules behind the answer
- A shared structure, national rules
- The OECD Guidelines set the master-file and local-file structure most European countries use. Each country decides who must prepare a local file, for which transactions, in what language and by when.
- Check how each threshold is measured
- Documentation thresholds can apply per type of transaction, per year or by the size of the company, and the measure differs by country. The SSC’s service charges and the loans may fall on different sides of the same line.
- Documentation comes with filings
- Poland requires an annual transfer-pricing information return and a statement that the local file was prepared. Other countries ask for related-party information with the corporate income tax return, or for documentation only on request within a short period.
- Low-value services may be simpler
- Many countries allow a simplified approach for low value-adding intragroup services. Whether the SSC’s accounting and IT charges qualify depends on each country’s conditions.
How it runs in azta
From the question to the document
The question, as you would type it
Polish SSC charges accounting and IT services to Czech and Slovak sister companies; the Czech plant sells goods to the Slovak distributor; the parent lends to all three. Values attached. For 2026, which local-file obligations, thresholds, deadlines and filings apply in each country?
You start with
The group’s intercompany agreements and a list of flows by entity and value
- 01
Upload the agreements and the flows
Add the intercompany agreements and a list of flows with values per entity. azta reads them and refers back to the passages it relied on.
File upload· Pro - 02
Research each country’s rules
Ask for the documentation duty, thresholds, deadlines and filings in Poland, the Czech Republic and Slovakia. azta cites the income tax acts and the regulations it holds.
Cited research· Free - 03
Build the outline
Ask for an outline per company with a table of flows, the threshold test and the deadline. Edit it in Canvas.
Canvas · Ask azta· Pro - 04
Hand it to the client’s team
Export the outline to Word so the group tax manager can assign each section.
Word export· Pro You send
An outline of the local-file requirements per country, with deadlines and filings
What you get
An outline of the local-file requirements per country, with deadlines and filings
Outline · draft
Local files 2026: Kraków, Ostrava and Žilina
Poland, Kraków SSC. The service charges to Ostrava and Žilina are tested against the Polish threshold for services, and the loans against the threshold for financial transactions. Where a threshold is exceeded, the local file is prepared by the statutory deadline and the information return and statement are filed. Values and deadlines: table 1.
Czech Republic, Ostrava plant. The sales to Žilina and the services and loans received are listed for the related-party disclosure with the corporate income tax return. The outline sets out the documentation the plant should hold to answer a request in an audit, using the OECD local-file structure.
Slovakia, Žilina distributor. The required scope of documentation depends on the company’s category under the Slovak rules. The outline lists what must be ready to hand over and the period allowed once the tax authority asks for it.
Outcomes on your numbers
What azta is worth on this task
Pro pays for itself after
11 minutes a month
At €160 an hour, that is all the time Pro (€27 a month) has to take off your desk to cover its price.
Example figures. Replace them with your own.
- Hours back a year
- 43
- Capacity at your rate
- €6,912
- More local-file outlines a quarter
- 1.5
- Return on Pro
- 21.3×
- Research
- Drafting
- Your review
A scenario you set, not a promise. The hours that come back go to another client, or deeper into this one.
Want these numbers on your team’s real workload?
Book a demoWhat stays with you
- The benchmarking and the arm’s-length analysis itself.
- Confirming values and counterparties from the ledgers.
- The group’s documentation approach and its sign-off.
Frequently asked questions
- Does azta prepare the benchmark?
- No. It researches the documentation rules and drafts the outline. Comparables searches and the pricing analysis stay with your transfer-pricing team.
- Can several advisors work on the same group?
- On Enterprise, a shared workspace keeps the group’s agreements, research and drafts together, with access by membership.
- Can it read agreements in Polish, Czech and Slovak?
- Yes. Upload them in their original language. azta reads them, answers in your language and refers back to the passages it relied on.
