Analytics
Transfer pricing / Service

Transfer Pricing Documentation

Documentation that explains the business context of a transaction and connects the narrative with the financial data.

Scope agreed before work beginsData, analysis and discussion
The deliverable

Local File documentation

  1. Transaction
  2. Functions and risks
  3. Financial data

A report with an explanation of the approach taken.

Who it’s for

Support shaped by your transactions.

For businesses preparing or updating Local Files for transactions with related parties.

01

Your first Local File

You need documentation for transactions with related parties.

02

Updating documentation

You have existing documentation, but the transactions or data have changed.

03

Organising information

You want to connect the business narrative, agreements and financial records in a coherent document.

Scope of support

What the work covers.

Each transaction has its own context. We agree the scope and organise the business narrative and supporting data.

Let’s define your project scope
01Identify transactions and documentation scope

We review the related-party transactions and agree which will be covered by the documentation.

02Analyse functions, assets and risks

We describe the parties’ functions, the assets used and the risks associated with the transactions.

03Document the transactions and financial data

We connect the business description with agreements, transaction records and the financial information provided.

04Review consistency across the documentation

We review the consistency of the document and identify matters that need clarification.

We agree any need for a separate benchmarking analysis or TPR support when defining the engagement.

Deliverables

The report. And the context.

01 / Report

Local File documentation

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

  • Business context
  • Functional analysis
  • Financial information
02 / Discussion

Room for questions.

We discuss the assumptions, findings and limitations of the report, and identify points that need further consideration.

Getting started

What to have ready.

01

Group entities and transaction overview

02

Agreements, transaction records and financial data

03

Existing transfer pricing documentation, if available

You do not need everything before our first conversation. We will tailor the data request to the agreed scope.

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 ↗
Analytical resources

Data selected for the transaction.

If the engagement includes benchmarking, we select sources to suit the transaction. TP Catalyst is also used by the Polish tax administration.

Explore our databases

Finding and comparing companies’ financial data.

Financial and business information on companies.

FAQ

Before our first conversation.

Can you work with our existing documentation?

Yes. We review its scope, the currency of the data and any changes to the transactions, then agree which sections need further work.

Is benchmarking included in the engagement?

We agree the documentation and analytical scope at the outset. If a separate analysis is needed, we include it in the proposed engagement.

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.

How can we help?

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Two or three sentences are enough. We will discuss the details together.

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