Modern manufacturing entities often operate in capital groups, and their role is sometimes limited to the function of cost centers. From the legal point of view, however, they are separate entities obliged to apply transfer pricing regulations. Meeting the requirements of the arm's length principle can be very difficult at this time, given the relationships and conflicts of interest in the capital group. Complexity increases in capital groups operating in different countries, due to differences in tax regulations. The main purpose of the paper is to demonstrate that the need to valuate the sale of finished goods to a manufacturing entity, which is a subject to a different tax jurisdiction, may lead to a problem of compliance with the arm's length principle. In addition, the paper proposes a methodology for comparability analysis that may be used by manufacturing entities to defend conditions of setting transfer pricing. The paper presents the different functional profiles of manufacturing entities and points out the difficulties that they may encounter when preparing the comparability analysis. It has also been noted that there are differences in transfer pricing regulations in different countries, for example by analyzing Polish and Czech regulations. The lack of uniform benchmarking legislation can cause inconsistencies in the selection of comparable data, resulting in differences in transfer pricing. The paper uses the method of legal regulation review and analysis of results of published studies concerning the scope of transfer pricing and comparability analysis. The paper also adopts a case study analysis.
 2016 Global Transfer Pricing Country Guide, Deloitte Development LLC, Stamford, CT, 2016.
 B. Chiang and B. Del Gaudio, “Transfer pricing and arm’s-length standard”, American Journal of Business Research, vol. 6, no. 1, pp. 49-62, 2013.
 L. Ching-Wen and C. Hsiao-Chen, “Motives of transfer pricing strategies - systemic analysis”, Industrial Management & Data Systems, vol. 110, no. 8, pp. 1215-1233, 2010.
 “Practical Transfer Pricing Issues. Comparability Analysis” Working Draft, UN Tax Committee, pp. 1-33, 2011, retrieved from: http://www.un.org/esa/ffd/tax/2011_TP/TP_Chapter7_ComparabilityAnalysis.pdf.
 J. Cooper, R. Fox, J. Loeprick and K. Mohindra, Transfer pricing and developing economies: A Handbook for policy makers and practitioners. Directions in development - Public Sector Governance. Washington, DC: World Bank, 2016.
 M. Franklin and J.J. Myers, “An analysis of transfer pricing policy and notable transfer pricing court rulings”, Journal of Business and Accounting, vol. 9, no. 1, pp.73-88, 2016.
 T.A. Gresik and P. Osmundsen, “Transfer pricing in vertically integrated industries”, International Tax and Public Finance, vol. 15., no. 3, pp. 231-255, 2008.
 M. Marques and C. Pinho, “Is transfer pricing strictness deterring profit shifting within multinationals? Empirical evidence from Europe”, Accounting and Business Research, vol. 46, no. 7, pp. 703-730, 2016.
 E.W. Maruszewska, “Implementation of enterprise resource planning system and change in accountant’s role - Polish perspective“, Management Systems in Production Engineering, vol. 2, no. 6, pp. 3-7, 2012.
 J. Mika, Ceny transferowe. Komentarz do rozporządzenia Ministra Finansów. Metody ustalania i szacowania cen transferowych. Analiza porównywalności. Warszawa: Wydawnictwo C.H. Beck, 2016.
 Model Tax Convention on Income and on Capital, OECD Publishing, Paris, 2014.
 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, OECD Publishing, Paris, 2010.
 S. Peraltaa, X. Wauthyb and T. van Yperselec, “Should countries control international profit shifting?”, Journal of International Economics, vol. 68, no. 1, pp. 24-37, Jan. 2006.
 Polish Corporate Income Tax Act of 15th February 1992, consolidated text of 26th October 2016, Journal of Laws of 2016, item 1888
 M. Shunko, L. Debo and S. Gavirneni, “Transfer Pricing and Sourcing Strategies for Multinational Firms”, Production and Operations Management, vol. 23, no. 12, pp. 2043-2057, Dec. 2014.
 A. Sulik-Gorecka, Wycena transakcji pomiędzy podmiotami powiązanymi. Ceny transferowe, Katowice: Wydawnictwo Uniwersytetu Ekonomicznego w Katowicach, 2010.
 Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris, 2015.
 United Nations Practical Manual on Transfer Pricing for Developing Countries, Department of Economic & Social Affairs, United Nations, New York, 2013