Tax Alert – transfer pricing
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...
Payment of the surcharge by a shareholder of the Company is subject to the obligation to prepare transfer pricing documentation – DKIS interpretation
On August 17 this year. The Director of National Treasury Information issued an individual interpretation (ref. 0111-KDIB1-2.4010.166.2020.2.AK) to determine whether the event consisting of adopting resolutions on the obligation of the sole shareholder to make...
Transfer pricing adjustment – obligation to apply the arm’s length principle at the transaction planning stage
In an individual interpretation of 4 August 2020. The Director of the National Revenue Information Office (KRIiK) stated that the mechanism used by the Company to increase its tax revenues or increase tax deductible costs on the basis of an accounting document other...
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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