Marek Firlej

Partner @SSW Pragmatic Solutions

Tax AdvisorFinance

Marek is the partner in charge of the transfer pricing practice with over 17 years of experience in tax law. He specialises in modelling intra-group settlements, implementing transfer pricing policies, and overseeing business restructurings between related entities. He provides services to clients in a range of industries including FMCG, real estate, IT (GameDev, software development), construction, cosmetics, pharmaceuticals, transportation, and advertising. He supervises documentation work covering all types of transactions between related entities, including those involving entities from so-called tax havens. Marek also assists in fulfilling obligations related to tax strategies. His professional experience includes roles in tax administration, primarily at the Ministry of Finance of the Republic of Poland. As head of the division, he led legislative work in areas such as natural resource taxation, GAAR, and tax information exchange. He represented Poland at OECD working groups on tax information exchange and aggressive tax planning, among other issues. Additionally, he was a member of the team responsible for issuing advance pricing agreements (APAs) and conducted proceedings mainly involving entities in the FMCG sector. Marek has shared his expertise in transfer pricing by conducting training sessions for representatives of tax authorities. In his role as a director at a national tax law firm, he supported business clients in meeting their transfer pricing obligations, prepared various types of transfer pricing documentation and analysis, and assisted clients during ongoing litigation. As a manager at a leading international consulting firm, he focused primarily on supporting clients through APA proceedings.

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