Tax Alert – transfer pricing

Due to the Covid-19 pandemic, on March 29 this year. The Ministry of Finance published a regulation extending certain deadlines for the preparation of stand-alone reports for 2020. (Journal of Laws 2021, item 572). Surprisingly, it turned out that the extension of...

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...

We would like to remind you that March 31 of this year is the deadline for filing the notification regarding the obligation to provide information on the group of entities (CBC-P) for taxpayers whose fiscal year coincides with the calendar year. This is because...

This position is confirmed by the judgment of the Voivodship Administrative Court in Rzeszów of 21 January 2021. (Case file I SA/Rz 841/20). In the facts described above, the applicant applied to the Director of the National Fiscal Information for an individual...

The transfer pricing analysis should cover one controlled transaction involving the attribution of income to the foreign permanent establishment(s), rather than several transactions involving the attribution of income or expenses of a certain type by source. The above...

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...