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Blog: Magdalena MICHAŁOWSKA

10 March 2021
Magdalena MICHAŁOWSKA

The Ministry of Finance has published draft tax explanations on transfer pricing regarding presumption and due diligence in transactions with tax haven entities. The draft explanations are now subject to tax consultation that will last until 20 April 2021. This consultation is open to all entities.

21 September 2020
Magdalena MICHAŁOWSKA

The revolutionary draft amendment of CIT and PIT Acts has recently been published amidst plenty of controversy, in particular about the CIT taxation of limited partnerships. This is one out of many changes suggested by the legislator and discussed in our Tax Alert. Important amendments that are supposed to enter into force in the beginning of 2021 include transfer pricing regulations, and that is what we are going to focus on in this article.

4 August 2020
Magdalena MICHAŁOWSKA

In today’s article we would like to give you some insight into transfer pricing adjustment regulated directly by the legislator in Article 11e of the Act of 15 February 1992 on Corporate Income Tax (hereinafter: CIT Act) and, respectively, Article 23q of the Act of 26 July 1991 on Personal Income Tax (hereinafter: PIT Act). We are also going to discuss the position of the tax authorities presented in relevant advance tax rulings that have been issued recently.