Transfer prices
Transfer Pricing – What does it mean?
The transfer pricing reporting deadline is fast approaching. Find out what transfer pricing is and whether it applies to your company!
Interest Rate Changes and Intragroup Loan Pricing
When determining the interest rate for loans between related parties, it is always necessary to check whether the proposed interest rate corresponds to market conditions at the time of the…
Irregular transactions between related parties in light of the judgment
Judgment of the Voivodeship Administrative Court of 25 February 2025 (Case No. I SA/Łd 781/24) and the role of TP documentation.
Last chance to submit the CbC-P
The CbC-P is an information form in which entities submit to KAS data on the entity obligated in the group to file the CbC-R.
APA as a tool for mitigating risks in transfer pricing
An APA is an agreement between a taxpayer and a tax authority, aimed at pre-establishing the rules for determining transfer prices in transactions between related entities.
What’s new in the latest version of the TPR Guide?
The Ministry of Finance has now published the fifth version of the TPR Guide.
Sanctions in the Fiscal Penal Code for a failure to
Along with the increase in the minimum wage in Poland, there have been changes in sanctions related to transfer pricing. These changes are significant, as from July 1, 2023, the…
TPR form and TP statement – change of submission method
The "Polish Deal" introduced several significant changes in the field of transfer pricing regulations.
Tax consequences of repealing the state of an epidemic threat
On May 2nd, 2023, a draft Regulation of the Minister of Health on lifting the state of epidemic emergency in Poland was published on the Government Legislation Centre website. The…
2023 in transfer pricing – what has changed?
The new calendar year means more regulatory changes for taxpayers. These changes have not spared the area of transfer pricing. What will change? What are the important deadlines? What should…
Transfer pricing sanctions in 2023
It has already become tradition that the new year means new changes in transfer pricing. At the end of last year, some of the regulations on verifying contractors for transactions…
Transfer pricing adjustments in 2023
The obligation of confirming transfer pricing adjustments made in the annual tax return was waived in 2023. Nonetheless, the subject of making adjustments remains valid.
What awaits us in Transfer Pricing in 2023
Introducing important dates related to transfer pricing in 2023.
December 31st is approaching – final days to prepare transfer
The deadline for preparing local transfer pricing documentation is near.
Polish Deal 3.0 – further significant changes in transfer pricing
The Act of October 7, 2022, signed by the Polish President, amending the act on corporate income tax and certain other acts, called the Polish Deal 3.0, will come into…
Transactions with tax havens – an attempt to liberalize current
On the 25th of August 2022, a government draft law amending the Corporate Income Tax (CIT) Law and other laws (the Draft), which partially takes into account comments received during…
Changes regarding transfer pricing documentation in Hungary
The 2023 budget law adopted in Hungary on the 19th of July significantly tightens the rules of corporate taxation along with the amount of fines that may be imposed. These…
Master File – aspects of this documentation method
Depending on the type of entity and a company’s income, transfer pricing documentation may be performed on two different levels — the Local File and the Master File.
Extension of TP deadlines
10.06.2022 r. The President signed into law the Law of June 8, 2022 on amending certain laws to automate the handling of certain matters by the National Tax Administration.
TPR Form – changes announced by the Ministry of Finance
Recently, the Ministry of Finance published new ordinance projects directed at the TPR-C and TPR-P forms.
Changes in transfer pricing from 1 January 2022
As of January 1, 2022, "The Polish Deal" introduced a number of new regulations that significantly affect taxpayers. The Act includes many key issues that directly affect affiliated entities. What…
Changes in interest rates and the company’s transfer pricing policy
In the article The November increase in the NBP reference rate affects the maximum interest rate in transactions between related parties, we wrote that in the environment of interest rate…
In some cases, the obligation to compile transfer pricing documentation
The new transfer pricing obligations are a consequence of the new wording of Article 11o of the CIT Act, which came into force on 1 January 2021.
Transfer pricing and the end of LIBOR rates
In2022, LIBOR basis rates are no longer being used, and this has consequences involving the regulations governing the use of the financial safe harbour mechanism.
An obligation to compile transfer pricing documentation for 2021 may
The new transfer pricing obligation is a consequence of the new wording of Art. 11o of the Corporate Income Tax Act, which came into force on 1 January 2021. Full…
The deadline for preparing transfer pricing documentation is approaching
The deadline for fulfilling transfer pricing obligations for 2020 is approaching rapidly. This year was an exceptional time due to the COVID-19 pandemic and its impact on transfer pricing. The…
2022 – a year of changes in transfer pricing compliance
Preparation of transfer pricing documentation, and compliance with all the duties related to transfer pricing, can pose a challenge each year for companies. One of the factors encouraging correct and…
