Affiliated entities should shape their mutual transactions and other economic events in such a way, so that the agreed terms correspond to market conditions, in particular, so that the price agreed within such a transaction (so-called transfer pricing) is according to the arm’s length principle.
Satisfying these obligations requires conducting comprehensive and complex comparative analyses (benchmark studies) aimed at determining the market price level for a given transaction. It should be noted that tax regulations applicable since January 2019 require taxpayers conducting transactions to hold appropriate comparative analyses for all transactions subject to the obligation of drawing up local transfer pricing documentation. Conducting such analyses without adequate tools, know-how and experience becomes extremely difficult or even impossible.
We are trying to meet market expectations halfway also in this regard by providing the following services:
- developing comparative analyses (benchmark studies) covering commodity and service transactions;
- evaluating financial transactions (interest on loans, warranties, sureties, cash-pooling, etc.);
- evaluating gratuitous or partially gratuitous benefits;
- evaluating intangible assets (including the royalty market level);
- verifying the benchmark studies held by the client in terms of them being adequate relative to a given transaction, and up-to-date and compliant with Polish regulations;
- verifying the impact of the COVID-19 pandemic on the validity of benchmark studies.
Benchmark studies based on the internal data of a client (provided they satisfy the comparability conditions set out in the legislation) or based on external data using professional databases also employed by tax authorities, such as, e.g., TP Catalyst, Quick Transfer Pricing Analytics (QTPA), Bloomberg, Royalty Range or EIKON.
