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Transfer pricing

What is a transfer price?

A transfer price is the price at which company sells goods, intangible assets or provides services to related parties. Each transaction between related parties should be arm’s length, otherwise the tax authorities may increase the taxable income by increasing revenues or decreasing costs. The assessment process is illustrated in the graph below (example for rendering services).


en_ceny_transferowe_desktop en_ceny_transferowe_mobile


Our services

In the area of transfer pricing, we offer the following services:

  • Preparing transfer pricing documentation.
  • Preparing benchmarking studies (click for more info).
  • Review of your transfer pricing documentation – checking its accuracy and completeness.
  • Restructuring intra-group transactions.
  • Preparing transfer pricing policy.
  • Developing internal procedures for workflow of documents within the group, in order to help you completing transfer pricing documentation (especially important, since new rules call for the statement on completion of the transfer pricing documentation to be submitted to the tax authorities).
  • Support and / or representing the company during the tax authorities’ transfer pricing audit.

Changes in transfer pricing regulations

Starting from 1 January 2017 new transfer pricing regulations are coming into force. One of the new requirements will be obligation to prepare a benchmarking study after exceeding a certain threshold of revenues or costs. It is a new rule in Polish tax regulations, since so far the benchmarking study was not explicitly defined. Also a way of preparing the benchmarking study was undefined and it resulted only from experience and practice. It is worth mentioning that even if in the given case the benchmarking study is not obligatory, still it is worth to draw it up, because it is an effective defense tool against the tax authorities attempts to assess income. Moreover, the tax authorities may examine whether the transaction conditions are in line with market conditions even if the threshold (beyond which a company is obliged to prepare a transfer pricing documentation or the benchmarking study) is not exceeded.

Benchmarking study is not the only new obligation introduced for transfer pricing purposes in 2017. The revised regulations introduce new duties on documentation and reporting. Other than in the past will also be thresholds for transactions and the types of required documents which will depend on the scale of operation of the entity.

Check your transfer pricing duties

What is the benchmarking study?

The benchmarking study is a statistical analisis of statistical financial data, designed to determine the market price level achieved by third parties in respect of a given type of transaction.

The benchmarking study significantly reduces the risk of dispute with the tax authorities as to the market price level agreed between related parties, which otherwise could lead to income assessment by the tax authorities. The benchmarking study provides evidence that the transaction result between related parties is arm’s length.

As part of our services we prepare benchmarking studies.

If you would like to initially check whether the prices used in your transactions with related parties are arm’s length, we invite you to use our “benchmarking calculator” (current version in Polish language only).

Transfer pricing calculator