Preparation of benchmark analyses
Comparative analysis, also known as benchmarking, is a mandatory element of transfer pricing documentation for most taxpayers performing intragroup transactions. The exemption from the obligation to have a benchmarking analysis applies primarily to micro or small businesses and transactions covered by simplified “safe harbor” settlement rules.
The purpose of the comparative analysis is to document the market nature of transactions between related parties by presenting data on transactions carried out in the market between unrelated parties or data on entities engaged in similar business activities.
In addition, the results of the comparative analysis are presented in the transfer pricing information in forms TPR-C or TPR-P.
Who is it for?
- Do you run a capital group with intra-group transactions?
- A new transaction is planned within your capital group?
- Have you carried out a reorganization within your capital group?
- Your company is part of an international group of companies performing intra-group transactions?
Our support scope - preparation of a comparative analysis for the transaction:
- commodities,
- services,
- financial,
- royalties,
- restructuring of operations.
Contact one of our experts on transfer pricing
Winning the case before the Supreme Administrative Court
on tax control for 2013 and determination of tax liability. Ref. act II FSK 585/20
Winning the case before the Supreme Administrative Court
regarding the Company's CIT exemption. Ref. act II FSK 1250/22
Winning case before the Voivodeship Administrative Court
on alleged abuse of VAT law. Ref. no. III Sa/Wa 203/22
Judgment of the Supreme Administrative Court, ref. no. I FSK 1816/20
The court objected to the very common approach among the tax authorities, but also often among the courts, of attributing an implicit awareness of participation in a fraud by pointing out that the evidence on the record did not show that such awareness existed. The court ordered that very precise criteria be taken into account that would make such awareness of fraud plausible.
