New group arrangements
You want to define pricing rules for selected transactions between group companies.
Transfer pricing / Service
Transfer Pricing Policy
We translate the group’s operating model into pricing principles that teams can apply in day-to-day work.
Scope agreed before work beginsData, analysis and discussion
The deliverable
Transfer pricing policy
- Business model
- Pricing principles
- Applying the policy
A report with an explanation of the approach taken.
Who it’s for
Support shaped by your transactions.
For groups establishing pricing principles or aligning policies across their entities.
A changing business model
Entities’ roles or transactions have changed and the policy needs a review.
Applying the policy
You need rules the finance team can use in day-to-day pricing and settlements.
Scope of support
What the work covers.
A useful policy starts with an understanding of the business. We connect the entities’ roles with calculation principles and their practical application.
Let’s define your project scope01Understand the operating model and transactions
We examine the group’s business model and the transactions in scope, including the current pricing arrangements.
02Define the roles of group entities
We describe the entities’ functions, assets and risks, and connect these findings with the remuneration model.
03Develop pricing and settlement principles
We develop calculation assumptions, the pricing basis and rules for the agreed transactions.
04Discuss practical application and data requirements
We discuss how the team will apply the policy and identify the data and further decisions needed.
The policy may cover one area or several transaction types. Additional analyses and implementation support are agreed separately.
Deliverables
The report. And the context.
01 / Report
Transfer pricing policy
Principles for the agreed transactions, including assumptions, calculations and practical application.
- Entities’ roles
- Pricing rules
- Data requirements
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.
Group structure and operating model
Agreements and current pricing principles
Financial data and available analyses
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.
Discussion and purpose
We establish the context, scope and approach.
Data and assumptions
We organise the information needed for the analysis.
Analysis
We select an approach and review the conclusions.
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.
Partner · tax adviser
Michał Kordiak
Specialises in transfer pricing, international taxation, financial modelling and valuations.
Court-appointed valuation expert
Talk to Michał ↗
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
Principles informed by analysis.
Where the project calls for an assessment of market terms, we select analytical resources for the arrangements — from operating activities to the use of intellectual property.
Explore our databasesCompany data to support the analysis of pricing arrangements.
Information on licensing agreements and royalty rates.
FAQ
Before our first conversation.
Can the policy cover selected transactions?
Yes. We can start with a specific area, such as intragroup services, and consider its connections with other arrangements.
What if the group already has a policy?
We review how it is applied and whether it reflects the current operating model. That review informs the scope of any update.
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.