RSM Poland


Transfer pricing

COVID-19 affecting transfer pricing – risks and challenges faced by related entities

12 May 2020
Tomasz BEGER
Zmniejszone przychody, zwiększone koszty, przestoje w produkcji, problemy z dostawami materiałów i surowców, osłabiona efektywność, niewypłacalność – to tylko niektóre z licznych negatywnych skutków, z którymi mierzą się przedsiębiorcy w obecnej sytuacji spowodowanej pandemią koronawirusa SARS-CoV-2. Kryzys gospodarczy wywołany wprowadzeniem w Polsce oraz w wielu innych krajach stanu zagrożenia epidemiologicznego oraz stanu epidemii związanego z rozprzestrzenianiem się koronawirusa stanowi zagrożenie również w kontekście wywiązywania się z obowiązków dokumentacyjnych i sprawozdawczych w zakresie cen transferowych. W niniejszym wpisie przedstawimy kluczowe ryzyka i wyzwania stojące przed podmiotami powiązanymi w zakresie cen transferowych w obliczu wirusa COVID-19.

COVID-19 pandemic and transfer pricing

7 April 2020
The current pandemic has a significant impact on transactions between affiliated entities. Deadlines for taxpayers’ obligations related to submitting declarations of the local file preparation and information on transfer prices remain effective, i.e. they fall on 30 September 2020. Under Art. 31z of the so-called special act the time limit has been extended until 30 September 2020 for entities beginning their fiscal year after 31 December 2018 and finishing before 31 December 2019.

Transfer pricing sanctions

16 January 2020
Tomasz BEGER
There has been a lot of talk about changes in transfer pricing regulations over the last 3 years.

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.


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