Tax Alert – transfer pricing
Application of minimum remuneration for surety in the light of administrative court judgments – judgment of the Supreme Administrative Court
On 18 November 2020. The NSA issued a judgment (II FSK 1949/18) repealing the appealed verdict of the WSA in its entirety and referring the case for re-examination. In the factual state described above, the company (the applicant) conducted business activity in the...
Should the free redemption of shares be treated as an economic activity? WSA judgment
On 17 November 2020. WSA in Poznań issued a judgment (I SA/Po 454/20) annulling the interpretation of the Director of National Revenue Information. In the described facts, the company (the applicant) and its shareholder applied for an individual interpretation of the...
Sales price adjustments as transfer price adjustment – DKIS interpretation
On 17 December 2020. Director of National Tax Information issued an individual interpretation (ref. 0111-KDIB1-1.4010.372.2020.3.BS) to determine whether the provisions of Article 12(3j) and Article 15(4i) of the Corporate Income Tax Act will apply to the adjustments...
Obligation to prepare transfer pricing documentation for a continued guarantee agreement in 2019. – DKIS position
On 22 September 2020. The Director of National Treasury Information issued an individual interpretation (ref. 0111-KDIB1-2.4010.250.2020.1.AW) to determine whether the Company is required to prepare transfer pricing documentation for a guarantee transaction concluded...
Obligation to prepare local transfer pricing documentation for the in-kind contribution of an organized part of the enterprise – DKIS interpretation
On 17 July this year. The Director of National Treasury Information issued an individual interpretation, ref. 0111-KIDIB1-1-4010.153.2020.5.ŚS in the scope of determining whether an in-kind contribution of an organized part of the enterprise to a limited partnership...
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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