Sep222025
Comprehensive market price analysis for a leading financial institution

Comprehensive market price analysis for a leading financial institution

MDDP supported one of the top financial institutions in Central and Eastern Europe in ensuring the transparency and compliance of intercompany transactions within its tax capital group. The client, a publicly listed company on the Warsaw Stock Exchange, plays a key role in the region’s financial markets by providing a robust trading platform for institutional and individual investors

Given the client’s status as part of a tax capital group, failure to meet market pricing conditions for intra-group transactions could have resulted in the immediate loss of taxpayer status, leading to significant tax liabilities and financial exposure. Therefore, ensuring that the remuneration applied to support services within the group adhered to the arm’s length principle was a critical aspect of this project.

MDDP executed a multi-stage, data-driven analysis to assess the compliance and economic rationale of the pricing methodology. The project involved:

  • Validation of pricing models – reviewing the correctness of pricing methodologies for various intra-group services, including cost allocation frameworks and indirect cost apportionment.
  • Benchmarking study – conducting a market-based analysis tailored to the financial sector to determine the appropriateness of applied pricing structures.
  • Optimization & risk mitigation strategies – recommending necessary adjustments to pricing methodologies to ensure full alignment with the arm’s length principle, while also implementing risk mitigation tools to prevent non-compliance challenges.
  • Regulatory compliance & strategic reporting – providing clear documentation and reporting strategies to substantiate pricing decisions for tax authority reviews, ensuring compliance across all non-statute-barred tax periods.

The project’s outcome was instrumental in securing long-term compliance with transfer pricing regulations, reducing tax risks, and reinforcing the financial stability of the tax capital group. MDDP’s tailored recommendations and in-depth analysis enabled the client to safeguard its taxpayer status while optimizing internal pricing structures.

The project was led by Magdalena Marciniak (TP) in collaboration with Magda Dymkowska (TP), combining deep industry knowledge with an innovative, risk-sensitive approach to transfer pricing.