In Olesiński & Wspólnicy we attentively watch trends and directions of tax regulations. Increasingly, apart from knowledge of legal regulations, advanced analytical knowledge and appropriate mathematical and statistical skills, come into play. To address the needs arising from the new regulations, we created a new entity – O&W Analytics.
Its specialists are supporting O&W Clients in implementation of tax law-compliant transfer pricing models, based on professional analyses of comparative data (benchmarking).
Transfer pricing and analysis of comparative data
Effective January 2017, requirements concerning obligatory transfer pricing documentation were extended. A significant number of taxpayers shall, apart from development of „traditional” documentation in descriptive form, be obligated to prove that prices and margins established in transactions with related parties are in line with terms and conditions agreed in transactions between third parties (Arm’s length principle). Analysis shall be based on collected comparative data.
Analyses of comparative data often consist of complex financial models requiring access to unique (restricted) financial data and comprehensive knowledge in the field of finance, risk assessment, statistics and econometrics.
Who is affected by the new obligation?
By 31 March 2018, taxpayers:
- with revenues or expenses exceeding EUR 10 million, or
- holding shares in a company which is not a legal person and, in the preceding year generated revenues or incurred expenses exceeding EUR 10 million,
shall develop an analysis of comparative data for transactions concluded with affiliated entities.
In accordance with the new regulations, analyses of comparative data shall be primarily based on comparative data from the Polish market.
Due to the nature of transactions concluded, the procedure of comparative data analysis is usually very comprehensive and includes acquisition of restricted financial data relating to similar transactions and statistical processing of such data.
Due to the highly specific nature of analyzed activity, the results achieved are often subject to comparability adjustments such as corrections arising from various level of risks assumed or assets employed by the parties to transaction.
O&W Analytics is a team of specialists with broad knowledge and experience in the field of finance, statistics and banking.
The team consists of analysts with professional experience in financial institutions, banks, consulting companies, graduates of reputable economic and technical universities.
Marcin combines thorough knowledge of finance with more than 15 years of international professional experience. He started his career at PricewaterhouseCoopers in Rotterdam, where he audited financial statements of multinationals, mainly reporting according to IFRS and accounting principles generally accepted in the U.S.
After 3 years in the Netherlands, he moved to Wroclaw, where during 4 years of working at PwC he was not only responsible for conducting audits of financial statements of subsidiaries of multinational companies reporting according to IFRS, Polish, American and British accounting principles but he also participated in advisory services such as Due diligence projects, initial public offering on the Warsaw Stock Exchange, reviews of business processes and of internal control systems. Since 2009 Marcin held a position of Operating and Finance Director of NK.pl, where he was as well involved in obtaining EU funds, participated in start-up accelerator programme and in due diligence processes. In January 2013, he took a position of Fund Accounting Senior Manager at Bank of New York Mellon, where he managed a team of more than 20 professionals responsible for migrating from Ireland a process of valuation of dozens of investment funds managed by a large European bank. Just before joining O & W Analytics, Marcin worked as Finance and Reporting Manager for an international packaging machinery producer Sidel (part of the TetraPak / TetraLaval Group), where he was responsible for creating an accounting team, implementing SAP ERP system and transferring to Wroclaw accounting and reporting functions for several Sidel Group companies domiciled in Western Europe and Russia.
Since 2004 Marcin has been a member of ACCA (Association of Chartered Certified Accountants). He speaks English fluently and communicates in Dutch. His passion is skiing, in his free time he is a fan of reading.
She gained a honours degree of the Faculty of Computer Science and Management of Wrocław University of Technology. She also completed postgraduate studies in financial analysis and business performance management at the Faculty of Management, Informatics and Finance at Wroclaw University of Economics...
She gained her professional experience in financial management in the financial institutions – the National Bank of Poland and the National Clearing House as well as commercial banks. Malwina specializes in financial analyzes, business valuations and investment appraisal. She also participated in projects on modifying budgeting processes, financial control and IT systems used in corporate management. In addition, Malwina develops her interest in the capital market. She speaks English fluently.
In her spare time she prefers mountain hiking, running, cinema or paintball.
Krzysztof graduated from Wrocław University of Economics with a degree in Finance and Accounting with specialisation of Management Accounting and Controlling. He gained his experience in consulting companies, dealing with corporate finance and strategic management...
In collaboration with KPMG Advisory, he participated in an international demerger project of one of the world’s largest corporations. Krzysztof also has extensive knowledge in the area of valuation and financial analysis, gained through the one-and-a-half-year experience in Venture Capital, where he was responsible for supporting dozens of portfolio companies in the areas of management accounting, controlling and preparation of information memoranda. He speaks English fluently.
Privately, he is passionate in start-ups and subjects of hostile takeovers. He is one of the lucky ones whose passion is linked with his work.