RSM Poland


Transfer pricing

What is new in transfer pricing (part 1)

13 June 2019
Tomasz BEGER
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.

Transfer Pricing Forum Recommendations – continued

22 May 2019
In this post, we are going to discuss the recommendations of Working Group no.3, which addressed re-invoicing and the hierarchy of transfer pricing methods. These recommendations have been prepared for transfer pricing regulations that have been in force since 1 January 2019.

Transfer Pricing Forum – recommendations

16 April 2019
Pursuant to the Regulation of 27 April 2018, the Ministry of Finance (hereinafter: MF) established the Transfer Pricing Forum (TPF) to respond to taxpayers’ needs concerning the clarification of different aspects of transfer pricing. The forum is a team comprising people who are professionally involved in transfer pricing, both as regards theory and practice, as well as the MF and the National Revenue Administration representatives.

New transfer pricing regulations: new challenges

8 March 2019
The turn of 2018 and 2019 is the time of publishing new regulations on transfer pricing. These regulations are included in Chapter 1a of the CIT Act and Chapter 4b of the PIT Act. On 29 and 31 December 2018, regulations of the Minister of Finance were published in the Journal of Laws, being secondary legislation to transfer pricing provisions.

Which tax regime to choose for your 2018 tax documentation?

19 February 2019
In 2019, taxpayers can choose the provisions according to which they will prepare tax documentation for the year 2018 that has just ended themselves. According to the amended provisions of the CIT Act and the PIT Act, taxpayers can apply provisions that are formally in force as of 1 January 2019 to group transactions concluded already in 2018. Preparing tax documentation according to the new regulations may make things easier for the taxpayer; yet, it may also generate new problems and obligations the taxpayer would not have to face, had they used the earlier regulations.

Landmark changes in transfer pricing

24 July 2018
Tomasz BEGER
The latest draft act, amending the Acts on Income Taxes and Certain Other Acts, published on 16 July 2018 is a harbinger of many comprehensive changes in transfer pricing. Less red tape and many simplifications for taxpayers are the principal goals the legislator had in mind. The draft act is now under public consultation, therefore its final wording is yet unknown.

The devil's not so black? – New regulations concerning transfer pricing

9 February 2017
The issue of changes in transfer pricing has been discussed for a long time now. The pompously announced revolution in transfer pricing has finally occurred – from the beginning of 2017, new regulations for determining the entities obliged to prepare tax documentation have been introduced along with a different than before method of qualifying the transactions that should be included in the transfer pricing documentation.

Transfer Pricing – is it worth preparing TP documentation on an ongoing basis?

1 June 2015
Undoubtedly, management of each related entity has to answer a question of whether to prepare tax documentation or choose to rely on luck instead, and a chance of not being summoned by the tax office to submit it. Or, if you have already decided to prepare the documentation, when to do it – during the tax year or after it finishes? Currently, almost each and every income tax control requires submitting TP documentation. One of the most committed errors between 1 January 2013 and 1 July 2014, in the case of  reduction of tax liabilities exceeding PLN 1,000, was lack of TP documentation[1]. This year, tax documentation will also constitute one of tax control priorities (vide The National Action Plan of Tax Administration for 2015).  

TP documentation versus a partnership

3 April 2015
The obligation to prepare tax documentation in the case of transactions by/with partnerships has been a source of confusion among taxpayers for a quite long time. To prepare or not to prepare? That’s the question! – such a paraphrase of the famous Shakespearian quote clearly illustrates the dilemma that many taxpayers have had to face.

Hello World: starting an adventure with Transfer Pricing

1 March 2015
Anyone who has ever had the pleasure of attending classes in programming almost certainly had the chance to plumb the mysteries of a programming language known as Turbo Pascal. If so, the phrase in the title of our first post surely sounds familiar. "Hello World" – the words our very first "programme" would usually display on the monitor of our computer. Back then, these two words meant the beginning of an adventure with a new, inspiring tool that would offer tremendous opportunities, namely programming. What better title could there be to celebrate the start of an adventure that may perhaps be different, but still as fascinating and inviting: an adventure with transfer pricing.