Transfer pricing adjustments – and who to believe?

Profitability adjustments (upward or downward) made between related parties consisting in the adjustment of the profitability level should not be subject to VAT either as an adjustment of the tax base for the supply of goods or as remuneration for the provision of...

Advance invoices not settled in a given tax year should be recognized up to the limits in a controlled transaction of a homogeneous nature – DKIS interpretation

On 14 January 2021. The Director of National Fiscal Information issued an individual interpretation (0111-KDIB1-2.4010.274.2020.2.AW) to determine whether advance invoices not settled in a given tax year are included to the limits in a controlled transaction of a...

Aviation Law provisions and exemption from transfer pricing documentation – DKIS interpretation

On 21 December 2020. The Director of National Fiscal Information issued an individual interpretation (0111-KDIB2-1.4010.443.2020.1.BKD) regarding the determination whether a taxpayer conducting transactions for which the price is determined based on the provisions of...

The services of secondment of employees of group companies are included in the list of revenues subject to withholding tax (WHT)

The subject of the court ruling issued by the WSA in Gliwice on 13 January 2021 (ref. I SA/Gl 1338/20) was the qualification of the services of secondment of employees to the relevant category of revenue indicated in Article 21 of the Corporate Income Tax Act....

Active regret for TPR-C information filed late

On December 31, 2020, the deadline for filing the TPR-C information by taxpayers for which the fiscal year coincides with the calendar year expired. In the event of failure to submit the TPR-C information to the Head of KAS by the due date, the obliged entities should...