Tax Alert – transfer pricing
Hedge transactions in the light of a report published by the OECD
Hedging is a strategy to hedge against the cost of changing exchange rates using appropriate financial instruments. A hedging transaction consists of a simultaneous conclusion of an opposite, opposite, unrealised transaction with an actual transaction. Hedging can be...
The OECD publishes transfer pricing guidelines for financial transactions
On 11 February 2020 the OECD published a long-awaited report containing transfer pricing guidelines for financial transactions. The report "Transfer Pricing Guidance on Financial Transactions: Inclusive Framework on BEPS: Actions 4, 8-10" also contains a number of...
Obligation to prepare transfer pricing documentation by an independent public healthcare institution – interpretation by the Director of National Treasury Information
On 3 February 2020 Director of National Treasury Information issued an individual interpretation (ref. 0114-KDIP2-2.4010.509.2019.1.SJ) on the obligation to prepare transfer pricing documentation by an independent public health care institution for transactions with a...
Corrections to declarations taking into account accounting notes issued by the supplier reducing the supplier’s margin and increasing the Company’s margin at WNT – interpretation by the Director of the National Treasury Information
On 28 January 2020 the Director of the National Revenue Information, an individual interpretation was issued (ref. 0114-KDIP1-2.4012.692.2019.1.RD) with regard to the correction of declarations taking into account accounting notes issued by the supplier reducing the...
Obligation to prepare a CIT-TP report – answer to the question
On 29 November 2019 an appeal No. 136 was filed concerning the obligation to prepare CIT-TP by taxpayers who, with respect to transactions carried out in 2018, took advantage of new regulations and thus did not exceed new documentation thresholds or took advantage of...
Information TPR-C new tool for selecting operators for inspection
As of 1 January 2019, the obligation for taxpayers to submit CIT-TP (PIT-TP) reports was replaced by the obligation to submit transfer pricing information (TPR-C). This means that from January 2020, taxpayers will in practice have to face the new obligation for...
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