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 […]

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 […]

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