Magdalena Dymkowska, Partner at MDDP and Head of the ETL GLOBAL Transfer Pricing Group
Over the past 15 years, Magdalena Dymkowska has specialised in transfer pricing and international tax, helping multinational groups manage complex cross-border transactions, compliance requirements and tax risks.
As a Partner in MDDP’s transfer pricing practice in Warsaw, one of the largest in Poland with over 50 specialists, she advises Polish and international businesses on transfer pricing policies, benchmarking studies, documentation, APAs and tax audits. Her work focuses particularly on groups that use Poland as a manufacturing, logistics or shared-services base for the wider CEE region.
MDDP is Poland’s largest independent tax advisory firm, and its transfer pricing practice is among the most awarded in the country. Magdalena has been recognised as a leading transfer pricing expert and a Women in Tax Leader in International Tax Review’s World Transfer Pricing ranking.
She is also Co-Leader of the ETL GLOBAL Transfer Pricing Group alongside Arely Almaguer, coordinating collaboration among transfer pricing specialists across the network.
In her day-to-day work, she particularly enjoys supporting multinational companies and SMEs as they expand internationally and address transfer pricing challenges across multiple jurisdictions.
What first drew you towards this profession or area of work?
My interest in tax and accounting started during my university studies, but discovering transfer pricing during an internship in a general tax department was largely a matter of chance.
What immediately attracted me to this field was its unique combination of tax, economics and finance. I also enjoy the opportunity to gain insight into different businesses and operating models, understanding how companies create value and organise their activities in practice.
What personal quality has been most important in your professional life?
If I had to choose one quality, it would be curiosity: the wish to understand how a business actually works before looking at it through a tax lens. In transfer pricing you rarely get the full picture from documents alone, and the real answers come from asking questions and listening to the people who run the operations. That curiosity, combined with a willingness to work through problems together with others, has shaped my career more than anything else.
What is a defining strength of your firm today?
MDDP’s defining strength is the combination of deep technical expertise and a genuinely business-oriented approach: with around 200 professionals covering every area of tax, we can put a full multidisciplinary team around a complex problem rather than answering only the transfer pricing part of it. As an independent Polish firm, we are close enough to the market to understand how our clients’ businesses really operate, and we focus on solutions that work commercially rather than only technically. That combination is also what makes us an effective partner for multinational groups managing their operations across several jurisdictions.
What does good client service mean in practice in your firm?
Good client service means being responsive, practical and truly understanding the client’s business. For example, when a client comes to us with a transfer pricing challenge, our role is not just to explain the regulations, but to find a solution that works in practice and supports their business goals.I believe the best client service is delivered when clients see us not only as advisers, but as trusted partners they can rely on when making important decisions.
In your experience, what is the most valuable aspect of being part of the ETL GLOBAL network?
The most valuable aspect for me is being able to reach a colleague who knows the local rules, the local authorities and the local practice, and to know that the answer will be reliable. In transfer pricing this matters more than in almost any other area of tax, because a position taken in one country has to hold up in every other country involved in the transaction. The network turns what would otherwise be a series of separate local opinions into one consistent, defensible approach for the client.
How would you describe your involvement in ETL GLOBAL beyond your work in the firm?
Beyond my role at MDDP, I serve as Co-Leader of the ETL GLOBAL Transfer Pricing Working Group alongside Arely Almaguer (Spain). In this role, I coordinate collaboration among transfer pricing specialists across the ETL GLOBAL network, facilitate knowledge sharing, and support the development of cross-border transfer pricing capabilities within the member firms.
One of the most rewarding, but also most challenging, aspects of this role is coordinating professionals from different countries, each operating within their own legal, tax and business environment. It requires balancing diverse perspectives, encouraging cooperation across jurisdictions and ensuring that we can effectively combine local expertise with an international approach.
Which current trend do you think matters most in your area of work?
The trend that matters most today is the growing impact of AI on the way clients access and evaluate information. With AI tools readily available, clients can often find quick answers to technical questions on their own, which means they increasingly expect advisers to provide more than just knowledge that can be found online.
In this environment, experience, judgement and the ability to understand context become even more valuable. While AI can help identify rules or possible solutions, it cannot fully replace professional expertise, particularly when it comes to interpreting complex situations, recognising risks, or understanding the commercial realities behind a transaction.
What clients need most today is someone who can read between the lines, challenge assumptions and turn information into practical advice. In my view, this human element, combining technical expertise with business understanding and professional judgement, will become even more important as AI continues to evolve.
Looking ahead, what matters most to you in the coming years, whether for your own work, your firm, or ETL GLOBAL where relevant?
Looking ahead, one of my priorities is to continue strengthening collaboration across the ETL GLOBAL network. The more we know each other personally and understand our respective areas of expertise, the easier it becomes to work together on international projects, share opportunities, and deliver seamless support to clients operating across borders.
I also believe that successful growth is about quality as much as quantity. As ETL GLOBAL continues to expand, I would like to see the network develop in a thoughtful and balanced way, particularly in regions where we are not yet represented, while preserving the collaborative culture and high professional standards that make the network so valuable.
What advice would you give to someone entering your profession?
Never underestimate the value of professional relationships. Technical knowledge is important, but success often comes from being able to connect with the right people, exchange ideas and learn from different perspectives. In the long run, a strong network will help you grow professionally and serve your clients more effectively.
