Tax Alert – transfer pricing
Exemption from the transfer pricing obligation if the Subsidiary with which the transaction is concluded and controlled settles with a tax haven
On 11 January 2022, the Director of the National Tax Inspectorate issued an individual interpretation with ref. no. 0111-KDIB1-2.4010.335.2021.1.DP on determining whether the Company will be entitled to benefit from the exemption from the obligation to prepare...
Transfer pricing obligations in the case of attribution of income (loss) to the Branch of the Company by the parent entity
On 3rd December 2021, the Provincial Administrative Court in Lublin, in the judgment of ref. I SA/Lu 431/21 on corporate income tax in the scope of determining whether the obligation to prepare transfer pricing documentation by the Branch includes a "controlled...
Keeping bank accounts falls within the definition of a controlled transaction – position of the ASC
On 18 June this year. The Director of the National Fiscal Information issued an individual interpretation 0114-KDIP2-2.4010.107.2021.1.RK regarding the determination of the value of controlled transactions for the maintenance of bank accounts. In the facts described...
Transfer pricing simplification package and the announcement of the ICAP Programme – news from the 12th Transfer Pricing Forum
According to the announcements of the Ministry of Finance presented by the Undersecretary of State of the Ministry of Finance, Jan Sarnowski, during the XII Transfer Pricing Forum, changes in the transfer pricing as part of the Polish Order are planned. According to...
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...
Establishment of documentation obligations between SPZOZ and Medical University and Clinical Hospitals – interpretation by DKIS
On 18 May 2021 The Director of the National Tax Information issued an individual interpretation (ref. 0111-KDIB2-1.4010.54.2021.2.MK) concerning the determination of whether a) the Medical University and the Applicant, for which the Medical University is the forming...
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