Analytics
Specialisation / 01

Transfer pricing

Consistent arrangements start with understanding the transaction.We support businesses with transfer pricing documentation, analysis and reporting.

Your starting point

Where do we begin?

Let’s establish which transactions your business carries out and where support is needed.

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Our services

Support at every stage.

Choose an area to explore the deliverable and the information useful at the outset.

01Transfer Pricing DocumentationDocumentation that explains the business context of a transaction and connects the narrative with the financial data.

Local File documentation

Documentation for the agreed transactions, covering the business context, functional analysis and financial information.

What to have ready

  • Group entities and transaction overview
  • Agreements, transaction records and financial data
  • Existing transfer pricing documentation, if available
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02Benchmarking & Compliance AnalysesWe assess transaction terms, select comparable data and explain how to interpret the analysis.

Benchmarking or compliance analysis

A report describing the approach, data sources, selection criteria and findings for the transaction.

What to have ready

  • Transaction details and the parties’ roles
  • Financial data and pricing calculations
  • Previous analyses, where available
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03Polish TPR ReportingWe organise the data for Polish TPR reporting and review consistency with the documentation and transaction records.

Data for Polish TPR reporting

An organised dataset and a record of points to resolve before completing the TPR information.

What to have ready

  • Transfer pricing documentation and analyses
  • Transaction values and financial data
  • Previous TPR information, if available
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04Transfer Pricing PolicyWe translate the group’s operating model into pricing principles that teams can apply in day-to-day work.

Transfer pricing policy

Principles for the agreed transactions, including assumptions, calculations and practical application.

What to have ready

  • Group structure and operating model
  • Agreements and current pricing principles
  • Financial data and available analyses
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05TP Reviews & Audit SupportWe review documentation and transactions, help clarify inconsistencies and support the preparation of responses during an audit.

Review findings

Structured findings, points to clarify and a proposed scope of further work.

What to have ready

  • Transaction documentation and analyses
  • Records of how the transactions operate in practice
  • Correspondence with the authorities, where relevant
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You do not need all the materials before our first conversation. We will tailor the data request to the agreed scope.

Databases and analytical tools

The data behind our analyses.

Access to specialist databases helps us select comparable data for the transaction — from operating activities to licensing and financing.

We work with databases also used by tax authorities.

TP Catalyst is used by the Polish tax administration, while RoyaltyRange is used by tax authorities internationally.

We select the data and analytical approach to suit the transaction and the purpose of the project.

Comparable data

Data for royalty rate analyses and intangible asset valuations.

Benchmarking

Finding and comparing companies’ financial data.

Financial markets

Bond and issuer information for financial analysis.

Business information

Financial and business information on companies.

LSEG Workspace

Financial data and analytics

Market data and analytical tools to support financial benchmarking and valuations.

Financing terms

Loan transaction data for comparing margins and financing terms.

Working together

A clear process. A shared goal.

01

Discussion and purpose

We establish the context, scope and approach.

02

Data and assumptions

We organise the information needed for the analysis.

03

Analysis

We select an approach and review the conclusions.

04

Results and discussion

We deliver the report and explain its assumptions.

The people behind the analysis

Talk to people who understand your challenge.

Tax knowledge, transaction experience and a financial perspective. Meet experts from the ILT team.

Michał Kordiak
Partner · tax adviser

Michał Kordiak

Specialises in transfer pricing, international taxation, financial modelling and valuations.

Court-appointed valuation expert

Talk to Michał ↗
Neil Kuczyński
Transfer Pricing Manager · attorney-at-law

Neil Kuczyński

Advises on transfer pricing policies, Local File and Master File documentation, benchmarking analyses and TPR reporting.

Talk to Neil ↗
Tools

Your first step towards clarity.

You do not need to know the name of a service. Choose the topic you would like to discuss.

Questions and answers

Good to know before we begin.

How do we start working together?

We begin by discussing your transactions, related parties and available data. This allows us to define the scope of work.

What data will be needed?

The data request depends on the transaction and service. We provide a list of information needed to begin the analysis.

Can the scope include TPR reporting?

Yes. We agree the scope of TPR reporting support separately, taking account of the available data and documentation.

Start a conversation

Let’s look at your situation.

Tell us about a planned transaction or a challenge. Together, we will determine the scope of the analysis you need.

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After receiving your enquiry, we will discuss the context with you and suggest the next step.

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