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Transfer Pricing Analyses (Benchmarking studies)
We prepare reliable benchmarking analyses, which constitute a key and mandatory element of local transfer pricing documentation (Local File). Our analyses confirm that the terms of controlled transactions comply with the arm’s length principle and meet the requirements of the Corporate Income Tax (CIT) Act. Regular updates - performed at least once every three years - help to mitigate the risk of income reassessment during tax audits and improve the organisation’s overall tax security.
Each benchmarking study we prepare is based on a professional selection of the appropriate method, considers both economic factors and regulatory requirements, and relies on reliable data sourced from recognised databases, such as Bloomberg Professional, Info Credit, TP Catalyst, and ktMINE.
Our offer:
We provide the following transfer pricing analyses:
- Benchmarking studies for financial transactions
We prepare benchmarking studies for financial transactions such as loans, bond issuance, cash pooling arrangements, and guarantees. We also assess the possibility of applying simplifications under safe harbour regimes. As a result, our clients are assured that financing terms align with the arm’s length principle and are defensible in a tax audit.
- Benchmarking studies for services
We prepare benchmarking analyses for service transactions, including intra-group services (e.g. administrative, marketing, or IT services). We also verify the possibility of applying safe harbour provisions for low value-adding services. Our analyses provide clients with robust justification for the arm’s length nature of service charges and reduce the risk of challenges from tax authorities.
- Benchmarking studies for goods transactions
We prepare benchmarking analyses for goods transactions involving the sale of products, goods, raw materials, and supplies, carried out under various functional models (from contract manufacturing to full-fledged manufacturers with significant functions and risks).
- Benchmarking studies for intangible assets
We prepare benchmarking analyses related to granting of licenses, provision of know-how, and transfers of intangible assets by identifying suitable comparable transactions.
- Compliance Analyses
Where sufficient comparable data is not available, we prepare compliance analyses using reliable alternative sources, including offer-based data. This approach provides an acceptable alternative justification for the arm’s length nature of transactions and helps minimise the risk of challenges by tax authorities.
Tomasz Jankowski
A tax advisor specializing in transfer pricing and corporate income tax. Author of numerous tax commentaries and opinions published in industry publications and expert websites.