Transfer pricing analysis

Why is it so important?


and in practice also the most important part of TP documentation


against multi-million upward adjustment that may be imposed but only if it is of high quality and confirms arm’s length nature of the transactions carried out.


in the event of a dispute with the tax authorities.

How can we help you?

  1. We will prepare a high quality transfer pricing analysis in the variant of:
  • benchmarking analysis and/or
  • compliance analysis.
  1. We will determine or verify the arm’s length level of remuneration for any type of intra-group transaction, including but not limited to:
  • services,
  • goods,
  • financial,

3. We will guarantee the high quality of the analyses since:

We will use professional databases (that are also accessed by tax authorities and global tax advisory companies) such as:

  • Infocredit QTPA (Poland),
  • TP Catalyst (BvD Amadeus - Europe, Orbis - World),
  • Bloomberg - financial transactions,
  • Royalty Range - licensing transactions.

We will analyze your internal transaction data - examining their potential for being a part of the transfer pricing analysis.

We will consider the relevant geographical area.

We will conduct a qualitative analysis of the sample - we will examine (reviewing data on websites), whether the entities in the sample meet the comparability criteria set out in the legislation.

We will ensure that the analysis complies with Polish and international TP regulations (including OECD Transfer Pricing Guidelines and Transfer Pricing Forum guidance).

We will select an appropriate transfer pricing verification method for the type of transaction and the profile of the entities involved in the transaction (and for selected methods, we will identify the party that should be subject to analysis).

We will use financial ratios consistent with the TPR Regulation to present the results (which will minimize the risk of their comparability being challenged by the authorities).

Benchmark as a multifunctional tool

Our transfer pricing analyses can be used not only for transfer pricing documentation, but also, to determine or verify the arm’s length nature of remuneration for all intra-group transactions (including those below thresholds). What's more, note that these analyses can later be used in other areas of taxation as well - for example:

WHT opinions

[Part of documentation to obtain opinion]

Attribution of profits to PE

Estonian CIT

[as an auxiliary when verifying whether the condition of having value added higher than negligible is met]

IP Box

[determining the income subject to taxation at a 5% rate]

To discuss other possible areas of application of transfer pricing analyses, please feel free to contact us.

What options for analysis are available?

Depending on your needs and materiality of the transaction, we offer 4  of analysis for goods and services transactions (while guaranteeing security and compliance).


Our qualitative analyses will give you a confidence and security when signing and submitting the statement on the preparation your transfer pricing documentation and the arm’s length nature of prices applied between related entities.

An individual approach

Our team of more than 50 experts, dedicated entirely to transfer pricing, supports clients with both simple and complex issues and, most importantly, provides prompt assistance.


None of our documentation and analysis has been challenged on a formal ground. We also support our clients in case of tax audits.

High-quality benchmarks

In just one week, we can prepare a complete high-quality benchmark to ensure your safety.


We focus on automating processes and saving customers' time. Our SMART.TP and SMART.TP-R applications streamline and accelerate the completion of documentation.

We have been on the market for 20 years

During this time, we have prepared several thousand documentation, several hundred transfer pricing analyses and dozen advance pricing agreements (APAs).

Feel free to contact us:

Magdalena Marciniak

Partner | Tax adviser | Head of the Transfer Pricing Practice
T: +48 665 746 360

Marta Klepacz

T: +48 533 889 036

Adrian Mroziewski

T: +48 505 294 041