We would like to remind you that the deadlines for completing transfer pricing obligations for 2021 are approaching. As a rule, the deadline should be 9 months after the end of the fiscal year; however, given the extended deadlines for the preparation and approval of financial statements, the deadline has been extended: to 30 September […]
Transfer pricing – proposed changes to tax haven transactions
The rules on indirect tax haven transactions have significantly expanded as of 2021. Due to their huge administrative burden, the legislator proposes their amendment. What is also important is that taxpayers will have the possibility to apply the new regime to transactions and in consequence, Transfer Pricing obligations, for 2021. According to our initial analysis […]
Changes in CIT Act
A proposition of amended CIT regulations was presented by Ministry of Finance. As of 1 January 2023, the planned changes are about to come into force. Withdrawal of “hidden dividend” regulations One of the most important changes is withdrawal of hidden dividend regulations which was to be introduced within Polish Deal 1.0. Hidden dividend means […]
The planned extension of transfer pricing deadlines
The expected bill with changes to the deadlines for fulfilling transfer pricing obligations in CIT and PIT has reached the Sejm. The presented proposals specify the extension of the deadlines: until 30 September 2022 for TP obligations with a deadline between 1 January 2022 and 30 June 2022, by 3 months for TP obligations with […]
Close deadline for submission of CBC-P notification
Pursuant to the Act on Exchange of Tax Information with Other Countries, the obligation to file a notification on form CBC-P applies to an entity that: has its registered office or management board in Poland or has its registered office or management board outside of Poland, but conducts business activity in Poland through a permanent […]
New transfer pricing obligations for transactions where the beneficial owner is located in a tax haven
In 2022, for the first time, taxpayers and companies that are not legal persons will face the obligation, introduced as of 1 January 2021, to prepare transfer pricing documentation if the beneficial owner in a transaction is an entity with its place of residence, registered office or management in a country or territory applying harmful […]
The Polish Order introduces changes to transfer pricing
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 […]