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...

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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...

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When carrying out a transaction with a civil law partnership, the value of the transaction should be determined in relation to the civil law partnership and not separately for each partner of the partnership – interpretation by the Polish Accounting Standards Board

On 2 June 2021 The Director of the National Fiscal Information issued an individual interpretation (ref. 0113-KDIPT2-3.4011.207.2021.3.MS) on whether, in the case of a transaction with a civil partnership, the value of the transaction is determined: in relation to the...

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There is little time left to submit the ORD-U

We would like to remind you that 31 March is also the deadline for submission of information on agreements concluded with non-residents (ORD-U) for taxpayers whose financial year coincides with the calendar year. The obligation to prepare and submit information...

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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...

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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...

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No need to document the dividend payment

In accordance with the amendment to the regulations in force since 1 January 2019, the documentation obligation is subject to controlled transactions of homogeneous nature whose value exceeds certain documentation thresholds. Controlled transaction means identified on...

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Economic strategy and economic conditions as important elements in determining the value of a controlled transaction between related parties – the judgment of the Voivodeship Administrative Court in Szczecin, sign. I SA/Sz 84/20 of 04.06.2020.

The verdict was issued on the grounds of an interpretation case in which the tax authority questioned the amount of revenues indicating their underestimation and therefore considered the prices applied by entities as deviating from market conditions. Therefore, the...

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The withdrawal of a shareholder from a commercial law company in the form of voluntary redemption of shares, regardless of its nature (voluntary or compulsory) implies the obligation to prepare transfer pricing documentation

In the individual interpretation of 10 June 2020 The Director of the National Revenue Office* explained that if a shareholder joins a commercial company in the form of a voluntary redemption of shares, regardless of its nature (voluntary or compulsory), there will be...

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Dobrowolne umorzenie udziałów

On 10 June 2020 The Director of National Revenue Information issued an individual interpretation (ref. 0112-KDIL2-2.4011.287.2020.2.AA), the subject of which was, among other things, to determine whether voluntary redemption of shares in a capital company without...

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Individual interpretation by the Director of the National Treasury Information concerning the determination whether the interest paid by the Company to the New Creditor, after subrogation, will constitute a deductible cost for the Applicant.

On 24 April 2020. Director of National Treasury Information issued an individual interpretation (ref. 0111-KDIB1-1.4010.47.2019.2.MF), as to whether interest paid by the Company to the New Creditor, after subrogation, will be deductible for the Applicant. This...

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Transfer pricing adjustment

On 7 April 2020 Director of National Treasury Information issued an individual interpretation (ref. 0114-KDIP2-2.4010.47.2020.1.SJ) regarding transfer pricing adjustment. The applicant's doubts concerned the determination whether making an income adjustment...

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Sale/acquisition by the Bank of investment certificates of the Funds for the purpose of their redemption, when the transaction price results from the Articles of Association is subject to transfer pricing regulations – DKIS interpretation

On 18 March 2020 Director of National Treasury Information issued an individual interpretation (ref. 0111-KDIB1-2.4010.502.2019.2.BD) to determine whether transactions consisting of sale/acquisition by the Bank of investment certificates of the Funds for the purpose...

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Transfer pricing information TPR-C

As of 1 January 2019, the obligation for taxpayers to submit CIT-TP (PIT-TP) reports was replaced by the obligation to submit transfer pricing information (TPR-C). TPR-C - for whom? This information concerns entities obliged to prepare local transfer pricing...

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Corrections to declarations taking into account accounting notes issued by the supplier reducing the supplier’s margin and increasing the Company’s margin at WNT – interpretation by the Director of the National Treasury Information

On 28 January 2020 the Director of the National Revenue Information, an individual interpretation was issued (ref. 0114-KDIP1-2.4012.692.2019.1.RD) with regard to the correction of declarations taking into account accounting notes issued by the supplier reducing the...

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