Tax Alert – transfer pricing
No obligation to submit TPR-C information for national transactions below the documentation thresholds – DKIS interpretation
On 24 July this year. Director of National Treasury Information issued an individual interpretation (ref. 0111-KDWB.4010.7.2020.1.KK) to determine whether there will be an obligation to provide information on transfer prices for those transactions that meet the...
Tax loss and exemption from the obligation to prepare transfer pricing documentation – DKIS interpretation
On 21 July this year. The Director of National Treasury Information issued an individual interpretation (ref. 0111-KDIB2-1.4010.184.2020.2.AR) concerning the determination of the possibility to take advantage of the exemption from the obligation to prepare local...
A company whose one shareholder is a State-owned enterprise is obliged to prepare transfer pricing documentation – DKIS interpretation
On 10 July 2020 Director of National Treasury Information issued an individual interpretation (ref. 0111-KDIB1-2.4010.210.2020.1.AW) to determine whether Article 11n(5) of the Corporate Income Tax Act excluding the obligation to prepare transfer pricing documentation...
The withdrawal of a shareholder from a commercial law company in the form of voluntary redemption of shares, regardless of its nature (voluntary or compulsory) implies the obligation to prepare transfer pricing documentation
In the individual interpretation of 10 June 2020 The Director of the National Revenue Office* explained that if a shareholder joins a commercial company in the form of a voluntary redemption of shares, regardless of its nature (voluntary or compulsory), there will be...
Extension of transfer pricing deadlines and obligation to comply with the transaction marketability clause
On 23 June this year, the Act of 19 June 2020 on interest rate subsidies on bank loans granted to entrepreneurs affected by COVID-19 and on simplified procedure for approval of the agreement in connection with COVID-19's application, the so-called Shield 4.0, was...
Dobrowolne umorzenie udziałów
On 10 June 2020 The Director of National Revenue Information issued an individual interpretation (ref. 0112-KDIL2-2.4011.287.2020.2.AA), the subject of which was, among other things, to determine whether voluntary redemption of shares in a capital company without...
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