There has been a lot of talk about changes in transfer pricing regulations over the last 3 years.
Transfer pricing is no longer a purely theoretical issue, but a factor to be taken into account on a daily basis in transactions with related entities. The number and nature of changes that taxpayers have to face in this area is quite challenging. And even though the most recent changes have entered into force as of 2019, taxpayers may decide to apply them to their tax documentation for 2018, as well.
At the beginning of the year significant changes were introduced in the provisions of the Corporate Income Tax Act, i.a. in the scope of the obligation to charge a flat rate income tax at source in connection with payment of remuneration to foreign entities.
As it usually happens with changes introduced into the tax law, on the quiet and through the back door a significant change is made as for the moment of including the effects of the issued (or received) invoice correction in corporate income tax/personal income tax calculation. Why is this moment so crucial?
From a board member's point of view, an entrepreneur's or that of a foreigner delegated to develop the company's branch in Poland, the subject question is of fundamental meaning. The answer, as is often the case with taxes, is unambiguous. It all depends on how apt you are to take on extra risks and how much spare time you may allow yourself to spend on solving tax riddles…