HOW CAN MDDP HELP YOU?

  • Preparation transfer pricing analyses

    We will prepare transfer pricing analyses (benchmarking / compliance analyses) that will help the market level of remuneration to be determined or verified for various types of intra-group transactions (services, goods, financial, licensing, etc.).

    By choosing our services, you can be sure of the high-quality of the analyses prepared since:

    • We prepare them with the use of professional databases (tax authorities and global tax advisory companies also have access to)
    • We conduct a qualitative analysis of the sample – we determine whether the entities in the sample meet the comparability criteria
    • We take into account the relevant geographic area
    • Our analyses are in line with Polish TP regulations, OECD guidelines and the guidelines of the Transfer Pricing Forum
    • We select the appropriate transfer pricing verification procedure and the party subject to testing in the transaction (for some procedures)
    • We use financial ratios consistent with the TPR Regulation, thanks to which the risk of the authorities accusing them of their lack of comparability is minimized
    • We analyse your internal transaction data in terms of the possibility of using them as part of the transfer pricing analysis
    • We determine whether COVID-19 has affected your operations and transactions, and if so, we will include this as part of our transfer pricing analysis.

    Our qualitative analyses will give you a sense of certainty and security when signing and submitting a declaration on the preparation of transfer pricing documentation and marketability of prices applied between related entities.

Why is it important?

Transfer pricing analyses are not only a mandatory but also the most significant element of TP documentation. Notably, a multi-million upward adjustment is a threat not only in the absence of transfer pricing analyses, but also when the analyses held by the taxpayer are of low quality and do not fulfil their purpose, i.e. fail to justify the market nature of the transactions performed.

Therefore, it is crucial to prepare high quality transfer pricing analyses, as only such analyses provide adequate security in the event of a dispute with the tax authorities.

Jakie warianty analiz są możliwe?
Commodity and service transactions Simplified option Standard option Extended option Extended option + COVID-19 impact
Assumptions for the verification of the arm’s length remuneration Automatic data selection Automatic and additional manual data verification on websites Automatic and additional manual data verification on websites with indication of the recommended point in the range Automatic and additional manual data verification on websites with an indication of the recommended point in the range with the impact of COVID-19 taken into account
Data bases Polish and European third-party databases Polish and European third-party databases Polish and European third-party databases Polish and European third-party databases and publicly available data on COVID-19 impact
Deliverables An analysis report in line with Polish tax regulations An analysis report in line with Polish tax regulations An analysis report in line with Polish tax regulations, together with the indicated point from the range An analysis report in line with Polish tax regulations, together with the indicated point from the range and conclusions of the COVID-19 impact analysis
Individual selection strategy
Automatic data selection
Additional manual data selection
Additional calculations / financial analysis corrections
Indication of the recommended point in the range
COVID-19 impact analysis
Substantive support by MDDP experts 2 h 4 h 4 h 6 h

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