Transfer pricing

Our approach

Our transfer pricing services go beyond ensuring regulatory compliance. As analysts experienced in broadly understood business advisory, we look at the client’s operations in a wider business context. We deliver analyses that are consistent with the actual operating model and can be used not only for documentation purposes, but also for management decisions. We rely on reliable databases such as Info Credit, LSEG Workplace, Royalty Range and TP Catalyst, as well as specialist analytical tools. In transfer pricing projects, we combine analytical and financial expertise with expert tax and legal knowledge within the OW Group.

Who we support

Our transfer pricing services are addressed to companies that belong to domestic or international capital groups and carry out transactions with related parties; are growing dynamically and need support in developing transfer pricing policies or structuring controlled transactions; carry out transactions with entities from so-called tax havens, which may trigger documentation obligations; enter into transactions with individuals who influence key business decisions, e.g. management board members.

Benefits

Our transfer pricing support not only ensures compliance with regulations but also delivers tangible business benefits.

analyses that support business decisions

Our transfer pricing analyses and valuations are not merely “compliance” reports. They provide data that has a real impact on margin management, cost planning and setting intra-group pricing policies. This allows our clients to make financial decisions based on facts rather than assumptions.

Reduced tax risk and dispute costs

A professionally prepared analysis compliant with current regulations significantly reduces the likelihood that settlements will be challenged by tax authorities. In practice, this means a lower risk of tax adjustments, interest and disputes that generate costs and affect reputation.

Market data from reliable sources

We use only recognised databases (QTPA, TP Catalyst, Royalty Range, LSEG Workplace), which means that our analyses are based on objective benchmarks rather than “estimates” or public databases of questionable quality.

Clarity in group procedures

Reliable analyses provide arguments for establishing a consistent transfer pricing policy across the group. This eliminates confusion, the risk of double taxation and internal conflicts in settlements between companies.

Readiness for tax audits

Complete, substantive analyses increase the level of security during tax audits. They are prepared so that they can be immediately submitted to tax authorities, supported by reasoning and data corresponding to Polish transfer pricing regulations, OECD guidelines and the recommendations of the Transfer Pricing Forum.

Transfer pricing services

Transfer pricing analysis for goods transactions

We determine the arm’s length level of profitability for trading activities, whether wholesale or retail. The benchmarking analysis is carried out using InfoCredit’s QTPA database, a source of current and historical financial data on more than 150,000 Polish companies, or Moody’s TP Catalyst database, which provides international data.

Transfer pricing analysis for service transactions

Using the QTPA or TP Catalyst database, we determine the arm’s length level of profitability for service activities, taking into account the functional profile of the service provider and the subject of the transaction.

Transfer pricing analysis for manufacturing transactions

Using the QTPA or TP Catalyst database, we determine the arm’s length level of profitability for manufacturing activities, taking into account the manufacturer’s functional profile, including fully fledged manufacturer, contract manufacturer and toll manufacturer models.

Transfer pricing analysis for financial transactions

We determine the arm’s length interest rate for loans, cash pooling, deposits, sureties, guarantees and bond issues, taking into account the debtor’s credit rating. For benchmarking financial transactions, we use the US-based LSEG Workplace database, which collects transactional data on financing agreements concluded on the international market.

Transfer pricing analysis for licence transactions

We determine the arm’s length level of royalties for the use of trademarks, patents and other intangible assets using the Royalty Range database, which contains transactional data on financing agreements, service fees and licences in the United States.

Transfer pricing analysis for restructurings

We determine the arm’s length value of remuneration for restructurings involving, for example, the transfer of contracts, know-how, fixed assets or an organised part of an enterprise.

Selected projects

Our experience encompasses a wide range of projects carried out for domestic and international corporate groups, in which we combine tax expertise with in-depth economic and financial analysis.

Benchmarking analyses for international capital groups across various industries

We have prepared several hundred benchmarking analyses for a broad range of controlled transactions carried out between related parties, both in Poland and within international structures.

Our projects are delivered for companies belonging to leading capital groups representing key sectors of the economy, including automotive, e-commerce, retail, food, shipbuilding and real estate development. Thanks to the experience gained in large and complex projects, we deliver analyses that not only meet regulatory requirements, but above all provide a solid market-based foundation for defending intra-group settlements before tax authorities.

Support during transfer pricing audits

Together with Olesiński i Wspólnicy, we have participated in tax audits in the area of transfer pricing as a real business partner actively engaged in dialogue with tax authorities. We conduct discussions aimed at defending the adopted approach and presenting the client’s business model consistently, combining tax arguments with economic analysis. A key element of our approach is the preparation and use of transfer pricing analyses that help substantiate the arm’s length nature of settlements and translate complex financial models into clear, persuasive and data-based arguments, including a consistent and substantively justified defence of the adopted benchmarking assumptions before tax authorities.

Valuations for restructurings and controlled transactions

We prepare valuations for controlled transactions, in particular as part of business restructuring processes within capital groups. These include, among others, the transfer of functions, assets and risks, including intangible assets, as well as the assessment of remuneration due to the parties to the transaction in line with the arm’s length principle. Our approach is based on in-depth economic and financial analysis, taking into account both the specifics of the business model and available market data, which allows us to prepare valuations that can be defended during tax audits.