Transfer pricing policy is a key tool of tax planning in multinational enterprises, enabling income allocation aimed at minimizing global tax burdens. The article discusses the importance and function of such policy as part of a broader tax strategy, emphasizing the need to balance optimization objectives with legal compliance—particularly with the arm’s length principle. It is shown that a roperly designed and implemented transfer pricing policy can deliver economic benefits while effectively managing tax risk. Special attention is given to the role of benchmarking in ensuring the tax security of the corporate group.
Bartosz Kubista (Fri,) studied this question.