Transfer Pricing and Settlement Policy

We provide comprehensive support in developing and implementing transfer pricing policies, as well as designing transparent intra-group settlement systems. We create practical, user-friendly solutions that comply with legal requirements and are defensible before tax authorities. The result is a coherent policy and clear settlement principles that ensure tax security in daily operations, facilitate group-wide communication, and support the preparation of transfer pricing documentation and reporting.

Our offer

Our products relating to intra-group settlement strategies include:

  • Transfer Pricing Workshop

An interactive workshop (online or on-site), during which we work with the client to identify functions, assets, and risks (FAR), select the appropriate transfer pricing method, and define the scope of documentation and required supporting materials.

The outcome is a clear and comprehensible pricing calculation tailored to the client’s functional profile. Optionally, the workshop may include customisation of Excel-based calculation tools.

  • Transfer Pricing Policy

Support in developing or updating a comprehensive transfer pricing policy for the entire group or selected entities. The policy defines pricing principles, roles and responsibilities of individual entities, and rules for reporting and documenting intra-group transactions. As a result, it serves as a practical management tool rather than just a formal document. Additionally, it promotes consistency across the group and facilitates communication with tax authorities.

  • Change in Transfer Pricing Settlements

Implementing a new policy or changing a settlement model requires a well-structured, carefully planned approach. We provide support in identifying areas needing adjustment (agreements, processes, systems), preparing communication and training materials, overseeing implementation across multiple locations, and organising workshops and Q&A sessions with key stakeholders (finance, tax, management, and operational teams). The outcome is a set of clear, sustainable rules embedded in the organisation’s day-to-day operations.

  • Transfer Pricing Policy User Handbook

The TP Handbook is a practical, simplified guide to transfer pricing principles applicable within the client’s organisation - designed for daily use by personnel in finance, accounting, controlling, tax, and contract administration. Its purpose is to translate the formal transfer pricing policy into operational guidance, ensuring that each user understands what actions are required, when and how they should be performed, and identifies relevant internal stakeholders with whom coordination is necessary.

  • Standardized Contract Templates

A professionally prepared set of standardised contract templates covering the most common types of intra-group transactions. The templates are fully aligned with the group’s transfer pricing policy and applicable tax regulations, serving to ensure compliance with the arm’s length principle while minimising tax risk.

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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.