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Radoslaw Byczyk

Radosław Byczyk


CMS Cameron McKenna Nabarro Olswang Pośniak i Bejm sp.k.
Budynek OMEGA/OMEGA Building
ul. J. H. Dąbrowskiego 79a
60-529 Poznań
Languages Polish, English

Radosław Byczyk is an associate in the Tax Team of the Corporate/M&A Department at CMS Poland.

He is an experienced expert who has advised the largest Polish and multinational companies in the field of transfer pricing for almost eight years.

Radosław specialises in developing and reviewing international tax structures, including transfer pricing models for transactions carried out by taxpayers, as well as developing transfer pricing policies. He also has extensive experience in preparing transfer pricing documentation and benchmarking analyses (including several sets of documentation and benchmarking analyses for various types of intercompany transactions).

Before joining CMS, Radosław worked for local Polish advisors and international consulting companies (‘Big Four’).

Radosław’s clients include companies that operate in a range of sectors of the economy, such as mining, banking, automotive, household appliances, and IT.

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Relevant experience

  • One of the biggest Polish capital groups from the mining industry: supporting the client in preparing for new transfer pricing documentation obligations, including the preparation of (i) transfer pricing documentation templates (Local files), (ii) a Master file, (iii) a transfer pricing policy, (iv) benchmarking analyses, and (v) Country-by-Country Reporting (CbCR).
  • One of the top Polish multinational groups from banking sector: preparation of a Master file for the Group. Day-to-day support in the area of transfer pricing, including: (i) a review of transfer pricing documentation prepared by the client, (ii) identification of the obligation to prepare CbCR.
  • Polish multinational group operating in the automotive sector: advice on the implementation of a new transfer pricing model within the Group, including: (i) identification of the key transaction flows in the Group, (ii) preparation of benchmarking analyses, (iii) developing a transfer pricing policy, (iv) transfer pricing risk assessment of the model implementation effects in various tax jurisdictions (Germany, Russia, Ukraine, Belarus, etc.).
  • Leading Polish insulation systems manufacturer: support in the preparation and participation in negotiations of a bilateral advance pricing agreement (APA) between the client and the competent authorities in Poland and Finland.
  • Leading Polish manufacturer from the automotive sector: preparation and update of transfer pricing documentation together with a transfer pricing risk assessment of cross-border transactions conducted with related entities.
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  • 2011 - Faculty of Management, Poznan University of Economics and Business, Poznan 
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29 Nov 19
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The new pro­vi­sions of the “Act of 16 Oc­to­ber 2019 on res­ol­u­tion of dis­putes over double tax­a­tion and the ex­e­cu­tion of ad­vance pri­cing agree­ments (the “Act”)” modi­fy and con­sol­id­ate the rules for...