Description of the method: the resale price method consists in lowering the price specified in the transaction of a given entity with an independent entity, regarding goods or services previously purchased by that entity from its related entity, by the resale price margin. The price determined in this way may be considered as the market price specified in the transaction of a given entity with an entity related to it.

This method is mainly used in trade in goods and is determined by reducing the price determined with an unrelated entity by the resale price margin. The resale price margin includes direct and indirect expenses related to a given transaction, excluding general and administrative expenses (ie operating costs of the entity as a whole and management costs of the entity) and the appropriate profit rate for a given type of transaction. Indirect costs must be allocated in accordance with accounting rules so that the calculation is made in accordance with the law. Attention should be paid, in particular, to possible changes in the value of things that took place before its sale to an independent entity. Such activities include, among others packaging, labeling, inward processing in all forms, etc.

The resale price margin does not include expenses equal to the price of the subject of the transaction and general management costs, i.e. operating costs of the entity as a whole and management costs of this entity.

The resale price margin is determined by reference to the level of the margin used by the same entity in comparable transactions with independent entities (internal comparison) or the margin used in comparable transactions by independent entities (external comparison). 

When determining the amount of the resale price margin, the following should be taken into account in particular:

  • factors related to the passage of time between the original purchase and resale, including changes in the market in terms of costs, exchange rates and inflation,
  • changes in the condition and degree of wear of things or rights that are the subject of the transaction, including those resulting from technical progress in a given field,
  • the reseller’s exclusive right to sell certain things or rights that may affect the decision to change the margin.

Comparability of transactions:  required by the provisions of Chapter 2 Study of the comparability of transactions in connection with Chapter 3 Methods of price verification of the Regulation of the Minister of Finance of December 21, 2018 on transfer pricing in the field of corporate income tax.

Mathematical formula:   CT = CR * (1 – m)


CT – transfer price
CR – price of an item in a transaction with an independent entity (internal comparison) or between independent entities (external comparison),
m – margin level used in transactions with independent entities or in transactions between independent entities.