Our key business object is boutique consulting services based on data.
We specialize in the area of transfer pricing, but also provide comprehensive support to our clients in other tax, accounting and legal areas. Our key strengths in the area of consulting include high professional skills, quick response time to our clients' needs, short decision-making path, flexibility and competitive prices.
In the area of consulting and benchmarking, we offer in particular:
✔ Comprehensive consulting and support in the area of transfer pricing for groups of companies, law firms and tax advisors
✔ Preparation of benchmarking analyzes and compliance analyzes, in particular for the purposes of transfer pricing, for all types of transactions
✔ Valuations of businesses and intangible assets
✔ Support in the scope of tax, legal and business consulting
See detailed information about the scope of our services available in relevant sections.
Areas of application
transfer prices, valuations, financial and intangible transactions, M&A, taxes, restructuring, MDR, TPR
Transfer pricing is one of our key areas of specialization. Our team consists of experts with many years of experience in consulting firms (including the so-called Big Four), groups of companies and public administration authorities, including the Ministry of Finance (where they were involved in, among other things, the introduction of new regulations in the area of transfer pricing, effective from 2019). We know and understand Polish and international regulations applicable to transfer pricing inside out, we follow any changes in this respect and analyze their impact on our and our clients’ business operations. We also participate on an ongoing basis in the work of the Transfer Pricing Center Association (www.cct.org.pl), understanding practical issues that businessmen and advisors struggle with in the area of transfer pricing.
Our support in the field of transfer pricing may include:
✔ Preparation / verification of local and master files
✔ Completion and submission of TPR-C or TPR-P forms
✔ Verification of transfer pricing obligations (documentation, reporting obligations) for a selected year or for the entire tax liability limitation period
✔ Analysis of settlements between a company and its foreign establishment, including assessment of whether income has been allocated to the foreign establishment in accordance with the arm's length principle
✔ Comprehensive audit of all settlements with related entities, including in terms of compliance with Polish regulations and practice, as well as the OECD Guidelines, along with identification of potential risks
✔ Development of a transfer pricing policy – both for transactions already concluded and planned – optimal both in terms of mitigating tax risk and the effectiveness of intra-group settlements
✔ Analysis and assessment of current issues and doubts in the area of transfer pricing, including assessment of tax implications of implemented or planned activities in the area of settlements with related entities and the choice of the most effective and safest method
✔ Support in the scope of business restructuring, including assessment of whether respective activities meet the restructuring criteria in terms of transfer prices; verification of the necessity to pay the exit fee and calculation of its amount
We specialize in the development of benchmarking analyzes and compliance analyzes for various types of transactions between related entities – with regard to goods, services, finance, intangible assets – based on data from both domestic and international entities. Analyzes performed by InfoCredit have become the synonym of the highest quality among our clients – domestic and international groups of companies and advisors, as well as tax administration authorities.
The solution created and constantly developed by InfoCredit – Quick Analytics (TP) – is the basic tool used for transfer pricing benchmarking in Poland. It is used by consulting companies, law firms, groups of companies, and tax administration authorities.
We prepare international analyzes based on the TP Catalyst tool created by Bureau van Dijk (currently Moody’s), whose a partner and data provider we are.
We prepare analyzes for both already completed and planned transactions, including:
✔ Service and goods transactions
✔ Financial transactions
✔ Transactions involving intangible assets
✔ Other transactions
See detailed information about the scope of our services available in the relevant sections.
We prepare these analyzes using Quick Analytics (TP) (ver. 2) - InfoCredit's proprietary database tool, which uses the resources of our database and is also commonly used for benchmarking analyzes by business operators, consulting companies, and tax administration authorities in Poland.
The benchmarking analysis will normally always consist of the following steps:
✔ Analysis of the information and documents received concerning the analyzed transactions
✔ Development of a suggested strategy to search out entities
✔ Conducting a search and selection of entities conducting comparable activities
✔ Conducting a statistical analysis of selected profitability ratios of identified comparable entities, most often based on multi-year data (the period of 3 or 5 years)
✔ Preparation of an analysis report
We prepare analyzes of financial transactions, including loans, guarantees/sureties or cash pooling agreements, mainly based on the BLOOMBERG Professional Terminal. This platform provides comprehensive data and specialized tools for analyzing various types of intra-group financial transactions in multinational companies. The platform provides access to information on over 6.1 million loans and bonds and 1.5 million companies and funds. The available tools enable analysis of risk profiles of pre-determined groups of entities, provide quotes from all global commodity markets and current economic information on the global financial market.
Granting / obtaining financing (e.g. a loan)
The methodology for preparing analysis for loan transactions based on external comparative data includes determining on the first place of the risk associated with the financing granted, and then searching out the database to find financing transactions concluded between unrelated entities and granted to entities with a similar rating, and then manually verifying their comparability with the analyzed transaction. The last step is to determined the interquartile range of comparable interest, which reflects the market level.
Guarantees / sureties
To verify / determine the arm’s length level of remuneration in transactions related to granting or receiving a guarantee / surety, we usually apply a two-sided approach, including a cost approach and a yield approach.
Analyzes of transactions involving intangible assets, e.g. in the scope of:
are most often carried out for the purpose of determining or verifying the arm’s length level of the license fee for using a specific asset.
Analyzes for this type of transaction are carried out using the following approach
✔ the Comparable Uncontrolled Price method based on comparative data from external databases (e.g. ktMINE)
✔ other market / income-based methods, if there is no possibility to identify external comparative data
Benchmarking analyzes are not only databases and profitability range calculations. Where possible and reasonable, we use internal data held by the analyzed entity or its counterparty for the benchmark purposes, in particular for the purposes of applying the Comparable Uncontrolled Price method. If necessary, we make required comparability adjustments to ensure that the highest comparability of data to the analyzed transaction is achieved.
Due to the limited availability of comparative data, analyzes based on the Comparable Uncontrolled Price method are less popular than analyzes based on the profitability of comparable entities. Nevertheless, the possibility of applying this method should always be checked in the first place, as it usually provides the highest degree of comparability to the analyzed transaction.
If it is not possible to prepare a benchmarking analysis, we prepare a compliance analysis to demonstrate the arm’s length nature of settlements between related entities.
A compliance analysis is most often carried out when there are no comparative data from unrelated entities available, caused either by the lack of entities conducting activities comparable to the analyzed transaction or the specificity of the market which is almost exclusively occupied by related entities.
To prepare a compliance analysis, we most often use:
✔ Information about the market, its specifics and market practice
✔ Analyzes conducted using data from related entities
✔ Verification and calculation of economic and non-economic benefits
✔ Analysis of realistically available options
✔ Generally available statistical data and industry analyzes
✔ Arguments proving that the transaction is generally reasonable in business terms
✔ Other information and data that may demonstrate the arm’s length nature of the transaction
Owing to our access to vast resources of financial data and other tools, we prepare valuations of companies (shares, stocks, organized part of companies – OPC) and intangible assets.
The valuations are prepared both for transfer pricing purposes (in which case the valuation approach and the content of the valuation report are in line with transfer pricing regulations), as well as for other purposes (e.g. for transaction, succession, credit security purposes).
We choose the valuation method according to the purpose of the valuation and specific features of the valued item (including the availability of comparative data obtained from relevant databases, such as ktMINE, Markables, Marketscreener, QTPA DealStats, and other). The methods we use take into account the requirements of legal regulations and standards of conduct applicable to determining the market value of a given valued item in accordance with national regulations and international valuation standards.
In a situation of material uncertainty, we use simulation analysis to estimate the narrowest possible range of values within which the market value should be located.
Our services:
✔ Brand and trademark valuations
✔ Technology, know-how, utility model, and patent valuations
✔ R&D work outcome valuation
✔ Software and copyright valuations
✔ Customer base and customer capital valuations
✔ Company share and stock valuations
✔ Organized part of company (OPC) valuations
✔ Start-up valuations
We provide these services together with Andrzej Podszywałow (wycenapraw.pl), a well-recognized expert in intangible asset valuation and risk analysis in the area of industrial property law and copyright law, as well as valuation of capital instruments and companies, a long-time court expert in the above-presented scope.
Wherever our clients need additional support, going beyond the area of transfer pricing, in cooperation with our trusted partners we offer comprehensive consulting services that comprehensively address issues reported in particular in such areas as:
✔ Taxes (in cooperation with experienced tax advisors) – including, but not limited to, WHT, IP Box, VAT, M&A, MDR
✔ Accounting and finance
✔ Legal advice
✔ Business advice
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