We offer assistance in the preparation, updating and verification of 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.
According to the legal status in force until 31 December 2018, the obligation to prepare a comparability analysis applies to taxpayers who are obliged to prepare domestic tax documentation and whose revenues in the year preceding the tax year exceeded EUR 10,000,000. Under the amended regulations, which entered into force on 1 January 2019, transfer pricing analysis is an obligatory element for transactions for which taxpayers defined the obligation to prepare domestic documentation (local file).
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
Below we present the most frequently used databases:
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