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The acquisition of shares for cash constitutes a controlled transaction.
On 29.03.2021 The Director of the National Tax Information issued an individual interpretation (0114-KDIP2-2.4010.29.2021.1.RK) regarding the determination of the possibility of exemption from the obligation to prepare transfer pricing documentation. The applicant is...
Who submits TPR information in relation to companies within the Tax Capital Group?
Related entities which are subject to the obligation to submit TPR information are companies forming PGK, and not PGK as a taxpayer. Therefore, each of the companies forming PGK is separately subject to the obligation to submit TPR information in relation to the...
How should transactions be grouped for inclusion in TPR information?
For the purposes of TPR information, a given transaction should be identified as a controlled transaction of homogeneous nature within the meaning of Article 11k(2), (3), (4) and (5) of the Act - i.e. in the same way as in local transfer pricing documentation. A...
Can transfer pricing information be signed by an attorney?
Yes. Signing the TPR information by an attorney is allowed on principles similar to signing other information or tax returns. However, other rules apply to signing the statement on preparation of local transfer pricing documentation referred to in Article 11m section...
How should I submit the TPR information?
The TPR form should be submitted to the Head of the Cashier by e-mail. The deadline for submitting the form for 2019 is the end of December 2020. (extended by 3 months due to COVID-19). The electronic pdf form was prepared by the Ministry of Finance and is available...
What is the recharacterisation of the transaction?
Under the amended regulations, the tax authority will be able to perform the so-called recharacterisation of a transaction with a related party and assess the tax consequences resulting from this newly classified transaction. It will also be able to consider that no...
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