On 23.10.2018. The Parliament passed a government bill amending the Personal Income Tax Act, the Corporate Income Tax Act, the Tax Ordinance Act and some other acts.

The Act introduces a number of changes in terms of transfer pricing, including:

  • introduction of legal definitions of key transfer pricing concepts,
  • the abolition of the documentary obligation for domestic transactions under certain conditions,
  • redefinition of related entities (extension of the catalogue of links),
  • determination of the documentation obligation,
  • conditions for the preparation of transfer pricing group documentation (Master file)
  • the introduction of simplified rules for (safe harbour) certain types of transactions,
  • conditions for adjustment of prices applied between related parties.

Author: Piotr Rzepka ? Tax consultant

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