The first change results from the draft Ordinance of 3 December 2019 introducing an amendment to the Ordinance of the Minister of Finance of 21 December 2018 on transfer pricing for corporate income tax.
In connection with the enactment of the Act of 16 October 2019 on resolution of disputes concerning double taxation and conclusion of advance pricing agreements, introducing the definition of advance pricing agreement. The amendment of the regulation in question consists in replacing the phrase “decision on the agreement” with the phrase “previous price agreement”.
The second reform is contained in the draft of 6 December 2019 concerning the amendment to the Regulation of the Minister of Finance of 21 December 2018 on transfer pricing documentation in the field of corporate income tax. This amendment is also of an adaptive nature and consists in replacing the terms “prior pricing agreement” and “unilateral prior pricing agreement” in this Regulation. which is replaced by the terms ‘transfer pricing agreement’ and ‘unilateral transfer pricing agreement’.
The amendments are made in order to avoid differences of interpretation.
Author: Izabela Lipka – tax assistant
