Comparability analysis

According to the legal status in force from 1 January 2019, the obligation to prepare a  basic local file documentation applies to taxpayers whom the value of controlled transactions exceeded:

Under the amended regulations, which entered into force on 1 January 2019, transfer pricing analysis is an obligatory element of local file tax documentation.

The analysis of comparability in accordance with statutory regulations should be prepared every 3 years. However, if there are significant changes in the taxpayer?s environment, changes in the industry in which the taxpayer operates, then such analysis should be updated before the end of this period.

Two statistical research methods are dedicated to the analysis of comparability:

The analysis of comparability may be made on the basis of one of the following formulas:

a) data on transactions carried out with independent entities
b) the selected database
c) industry reports
d) other documents in the so-called description of compliance.

We offer assistance in the preparation, updating verification of local file documentation and comparative analyses whose role is to justify that the conditions mean the level of prices and margins applied by related entities is comparable to the conditions in transactions occurring in comparable transactions concluded by unrelated entities.

Below we present the most frequently used databases: