On April 16-17, 2026, our Transfer Pricing Centre Association will organise its annual thematic workshops for its members.
I have the pleasure of co-organising this event, presenting a difficult issue, and discussing it with the participants.
Workshop topics
Below is the presentation schedule, topics, and speakers/discussion moderators.
- 10:00–11:00 What’s new in benchmarks and data management – Agnieszka Figiel / Grzegorz Garbarczyk
- 11:00–12:00 Functional profile and transfer pricing – Kamil Jaśkiewicz
- 12:00–13:00 Pillar 2 – Practical challenges – Monika Noga
- 14:35–15:30 Using AI to improve the quality of reporting and TP processes – Anna Krzemińska
- 15:30–16:30 Updates to the OECD Model Tax Convention (Article 9) – Sylwia Rzymkowska
- 10:00–11:00 TP cases – what’s new? – Krzysztof Liszka
- 11:00–12:00 E-invoicing and e-reporting – Marek Paciorkiewicz
- 12:00–13:00 Verification of the royalty rate benchmark (SPEEM) – Andrzej Podszywałow
- 14:35–15:30 Panel discussion: “What to expect in 2026?” – moderated by CCT
My Topic – Verification of the Rate Benchmark using the SPEEM method
Description of the problem
The problem at hand involves determining the royalty rate for the use of intellectual property (IP). Sometimes, the unique nature of the contract’s subject matter makes the results of a comparative analysis unreliable. The same problem arises in the niche field of exploitation and in the specific contract’s terms. The low reliability of the analysis is frequently due to the small number of comparable contracts. The wide range of royalty rates also decreases the confidence in the result. It is sometimes the case that comparable transactions are lacking.
In such a situation, we use a so-called “valuation technique” to determine, verify, or narrow the range of royalty rates.
Proposed solution
Intangible asset valuation standards include the following methods: EEM/MEEM – (Excess Earnings Method) / (Multi-period Excess Earnings Method).
When valuing goodwill, brands, customer relationships, know-how, and so on, we capitalise or discount future cash flows/excess earnings. We can also use the SPEEM Single-period Excess Earnings Method to verify or assess the implied royalty rate.
In all cases above, we need to identify the profit generated by a licensed IP portfolio. This approach allows us to consider the unique characteristics of the IP’s field of exploitation. It considers the profitability and capital intensity of the exploitation field.
I will discuss a specific case study of verifying the royalty rate using financial and transactional parameters obtained from publicly available and commercial databases. The presented model utilises simulation analysis and does not require revenue forecasting (it is based on financial indicators).
Conditions of participation in the workshops
Workshops are available only to Association members.
For 10 years, we have also organised an annual conference that has always attracted leading consulting firms and institutions, including distinguished experts from the Ministry of Finance. This year, we are launching webinars open to CCT members called “Sip of Power.” These online events are dedicated to current practical issues in transfer pricing.
I am posting a link to the CCT Association profile on LINKEDIN https://www.linkedin.com/company/centrumcentransferowych/?originalSubdomain=pl.
CCT primarily brings together transfer pricing practitioners from Poland’s largest capital groups. Detailed membership rules are outlined in the Association’s statute.
My role as Vice President of the CCT Association Board obliges me to inform those interested in participating in the Association’s work. I invite you to contact me.
