Benchmarking w dokumentacji cen transferowych – wybrane aspekty
Benchmarking in transfer pricing documentation – chosen aspects

Summary/Abstract: Companies often deal with their affiliates. If they exceed their 2 million euros accounting revenues (costs) in 2017, they must prepare transfer pricing documentation for the year 2017. In case of exceeding the amount of EUR 10 million, taxpayers will additionally have to carry out the analysis of comparative data. It could be done by internal or external comparison. From a transfer pricing point of view, internal benchmarking is supposed to help the internal comparison through the collection of relevant data and their systematization, in particular transactions (other events) carried out by the taxpayer and the unrelated companies. On the other hand, external benchmarking should be used for transactions (other events) performed between other (independent) companies. The aim of this article is to present benchmarking possibilities in comparative data analysis. The realization of this goal was connected with the use of critical review of literature and legislation as research methods.

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