Tax Alert – transfer pricing
The deadline for submitting information on agreements concluded with non-residents expires
Pursuant to Article 82(1)(2) of the Tax Ordinance, all entities conducting business activity are obliged to draw up and submit information on agreements concluded with non-residents within the meaning of foreign exchange law (ORD-U). As a rule, the information of the...
A cash contribution to a company is subject to the obligation to document – DKIS interpretation
On 15 May 2020 the Director of the National Revenue Administration issued an individual interpretation (ref. 0111-KDIB1-2.4010.81.2020.2.MS) to determine whether a cash contribution is subject to the obligation to prepare transfer pricing documentation. In the...
Adjustment of transfer prices and adjustment of tax deductible costs – DKIS interpretation
On 8 May 2020 Director of the National Revenue Administration issued an individual interpretation (ref. 0111-KDIB2-1.4010.55.2020.2.MK) to determine whether transfer pricing adjustments made by related parties will entitle the Company to adjust tax deductible costs...
The Company and its foreign plant are related entities – interpretation by the Director of National Treasury Information
29 April 2020 The Director of National Treasury Information issued an individual interpretation as to whether the Company is obliged to prepare transfer pricing documentation for transactions with its foreign plant. In the described facts, the Applicant opened a...
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...
“Questions and answers on TPR-C and TPR-P information for 2019” – tax consultations
Since 1 January 2019, the amended transfer pricing regulations have been in force. One of the new obligations imposed on taxpayers is to submit information TPR-C/ TPR-P instead of CIT-TP/ PIT-TP. Entities which execute transactions with related entities exceeding the...
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