Tax Alert – transfer pricing
The increase in NBP interest rates and comparative analyzes
The Monetary Policy Council of the NBP (MPC) raised interest rates once again. On February 8, 2022, the Monetary Policy Council decided to increase the reference rate by 0,50 percentage points. i.e. from 2.25% to 2.75%. Thus, an increase in interest rates may have an...
It is impossible to apply for the exemption from the obligation to prepare local transfer pricing documentation in the event of a loss on the source of revenues, while this loss was not the result of a controlled transaction.
On January 20, 2022, the Director of the National Tax Inspectorate issued an individual interpretation with ref. no. 0111-KDIB1-3.4010.625.2021.2.MA on determining the possibility of using the exemption from the obligation to prepare transfer pricing documentation for...
Purchase transactions from the perspective of the taxpayer are subject to verification for the emergence of a documentation obligation in respect of “haven transactions” – interpretation of the ASC
On 19 January 2022 The Director of the National Fiscal Information issued an individual interpretation (0111-KDIB1-2.4010.385.2021.1.AW) regarding the determination of the lack of the obligation to prepare transfer pricing documentation under Art. 11o of the Corporate...
Exemption from the transfer pricing obligation if the Subsidiary with which the transaction is concluded and controlled settles with a tax haven
On 11 January 2022, the Director of the National Tax Inspectorate issued an individual interpretation with ref. no. 0111-KDIB1-2.4010.335.2021.1.DP on determining whether the Company will be entitled to benefit from the exemption from the obligation to prepare...
Transfer pricing obligations in the case of attribution of income (loss) to the Branch of the Company by the parent entity
On 3rd December 2021, the Provincial Administrative Court in Lublin, in the judgment of ref. I SA/Lu 431/21 on corporate income tax in the scope of determining whether the obligation to prepare transfer pricing documentation by the Branch includes a "controlled...
Keeping bank accounts falls within the definition of a controlled transaction – position of the ASC
On 18 June this year. The Director of the National Fiscal Information issued an individual interpretation 0114-KDIP2-2.4010.107.2021.1.RK regarding the determination of the value of controlled transactions for the maintenance of bank accounts. In the facts described...
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