The draft Polish Governance Act introduces further changes to transfer pricing (TP): New penal fiscal sanctions failure to prepare local transfer pricing documentation, preparation of transfer pricing documentation not in line with actual background, failure to submit information on transfer pricing (so-called TPR form), or submitting information that does not correspond with the local transfer […]
Changes within the framework of the Polish New Deal may also affect transfer pricing
On the website of the Ministry of Finance (MF) has been published another package of legislative proposals in connection with the announced Polish New Deal. This time, the proposals of the MF will concern transfer pricing. In principle, the aim of the proposed changes is to make it easier for taxpayers to meet their transfer […]
The Ministry of Finance presents a draft of explanations regarding the due diligence obligation related to transactions where the beneficial owner of the payment is located in a tax haven
Regulations regarding settlements with tax havens have been part of the TP regulations since 2000. Since then, obligations to document transactions with related entities were indirectly transferred to settlements executed by taxpayers with tax haven-based entities. At the end of 2020, the legislator took a big step forward by incorporating changes to regulations regarding settlements […]
New statistics on Advance Pricing Agreements (APA) applications
At the end of January, the Ministry of Finance (MF) published the most up-to-date statistics related to the Advance Pricing Agreements (APA) procedure. Updated as of 31 December 2020, the data summarises already 15 years of this legislation in Poland. For several years, the number of pricing agreements concluded by the MF with taxpayers has […]
Further significant changes to the TPR-C form
The Ministry of Finance[1] (MF) is not slowing down in carrying out work aimed, as declared, at more effective prevention of understatement of taxable income in the area of transfer pricing. Changes in TP introduced shortly before the end of the year are unfortunately becoming a tradition. This time, taxpayers filing transfer pricing information (TPR-C) […]
New obligation for 2021 – TAX STRATEGY
As of 2021 (i) taxpayers with revenues exceeding EUR 50M annually as well as (ii) tax capital groups are obliged to prepare and publicise information about tax strategy realized in the tax year. This in fact means the obligation of preparation of a tax procedure describing the process of carrying out tax compliance. We believe […]
Settlements with tax authorities as of 1 January
Significant changes in the context of the structure of the tax offices are upcoming as of 1 January 2021 for entities of strategic importance for the economy. One national and 19 local specialized tax offices Establishing one specialized tax office of a national range for a group of key taxpayers, including taxpayers with revenues exceeding […]
Transfer pricing obligations across CEE countries (Poland, Czechia, Slovakia, Hungary) in 2019 – 2020
Transfer pricing regulations around the world grow at a fast pace as a result of the implementation of the Action Plan on Base Erosion and Profit Shifting (BEPS) developed by OECD in national tax environment recommendations. Local regulations introduce specific transfer obligations that are relevant exclusively for local entities, such as Transfer Pricing rules applicable for Polish CIT and PIT […]
The deadline for submitting IFT-2R has been extended
On 29 May 2020 the new Regulation has been issued by the Minister of Finance as regards the IFT-2R information, i.e. information on the amount of revenue (income) generated by taxpayers of corporate income tax having no registered seat office or management board in Poland. In accordance with the new Regulation the deadline for submitting […]
Comparison of CIT-TP and TPR – Part 1: General information
The purpose of this publication is to summarize basic differences between CIT-TP form (submitted by larger taxpayers in recent years) and its new equivalent – TPR form. A wider range of related parties will be required to submit the TPR form. In the publication, we compare the two forms based on regulations of the Corporate […]