Expert portal on transfer pricing · site owner: DMS TAX Sp. z o.o., tax advisory company
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Profitability and transaction comparability analyses

Transfer pricing analyses (comparability analyses, compliance analyses)

Together with Origodata we help clients determine the market value of planned transactions between related parties, estimate historical values and assess whether the transfer pricing settlement models applied are justified, as well as design and implement settlement systems for groups of related parties. Our main task is to prepare a sound analysis of historical and planned data under defined transaction conditions, in such a way that the objectives set for the company can be met and legal and tax risks reasonably minimised.

Range of services

Within transfer pricing analyses and valuations DMS TAX provides the following services:
  • Comparability analyses of a transaction carried out between related parties, covering a comparison of financial data, including commercial data, either internally, on the basis of the client's own data on identical or similar transactions, or externally, on the basis of market data on comparable transactions, according to objective comparability criteria.
  • The purpose of a transaction comparability analysis is to substantiate the arm's length character of transactions with related parties on the basis of the results the client achieves in comparable internal transactions or, in an external comparison, the results achieved by independent entities.
  • Profitability analyses, which consist in examining the level of profitability of the client's business activity against comparable entities on the Polish market in a given financial year or over a number of years, using aggregated data and objective comparison criteria.
  • The purpose of a profitability analysis is to substantiate the arm's length character of transactions with related parties on the basis of the results achieved by comparable entities on the Polish market in a given period. The analysis examines overall profitability at the level of return on sales and of operating activity. In certain justified cases other financial ratios are examined as well, including gross and net margin or result, ROA and ROE.
  • Valuations of individual tangible and intangible assets, of organised parts of an enterprise, of an entire enterprise or of shares and stock.

When preparing analyses we draw on a variety of data, including data from the Origodata database. Origodata holds a database with information on more than 200,000 Polish companies, making it possible to analyse commercial transactions, corporate bonds and many other financial aspects comprehensively. This allows transactions on the financial market to be analysed sensibly, in particular with the specific features of the Polish market in mind. Origodata also offers support in designing and implementing settlement systems for groups of related parties. A professional transfer pricing analysis requires detailed historical and forecast data to be gathered so that the company's objectives can be achieved and legal and tax risks minimised, something DMS TAX, as a tax advisory company, has confirmed many times in the audit and tax proceedings it has handled. Together with Origodata, DMS TAX carries out comparability analyses covering the comparison of financial data, both internal, based on the client's transactions, and external, based on comparable market data, in line with objective criteria. The aim is to substantiate the arm's length character of transactions with related parties. Origodata also performs profitability analyses, examining the level of profitability of the client's activity in comparison with other entities on the Polish market, which helps to substantiate that the transaction is in line with the market. In addition, it offers valuations of assets, of organised parts of an enterprise and of shares and stock. See more at origodata.pl. We will gladly provide detailed information about transfer pricing analyses and valuations. Please get in touch with our advisors.

See also the scope of the service comparability analyses, market analyses and valuations.