RSM Poland
Languages

Languages

Transfer pricing insights

Expert look at changes in transfer pricing regulations. We observe, analyse and propose solutions that comply with the provisions of the corporate and personal income tax acts, secondary legislation, and the current position of the Ministry of Finance. Do you enter into transactions with related entities? Read the Transfer pricing insights on our RSM Poland Blog - an informative and inspirational source of knowledge related to transfer pricing.

Tax havens: new documentation obligations

7 May 2021
Kamila DOBOSZ
Changes concerning transfer pricing in transactions with tax havens, effective as of 1 January 2021, will be challenging for taxpayers. Under the new regulations, there is an obligation to have verify whether transactions where the beneficial owner has its place of residence, registered office or management in a tax haven comply with the arm’s length principle (and it is unclear whether the legislator means the actual owner of our contractor or the cash flow generated as a result of a given transaction, as the regulations fail to specify this). What is more, taxpayers must provide economic justification for their transactions with tax havens.

Impact of the COVID-19 pandemic on transfer pricing - OECD Guidance

19 April 2021
Tomasz BEGER
The Organisation for Economic Co-operation and Development (hereinafter: OECD) has published the long-awaited Guidance on transfer pricing implications of the COVID-19 pandemic (hereinafter: Guidance). It includes comments and explanatory remarks that both taxpayers and tax administrations should take into account in evaluating the implementation of transfer pricing policies in the face of extraordinary economic conditions caused by the COVID-19 pandemic.

Draft tax explanations on transfer pricing regarding presumption and due diligence

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.

New TPR-C form: new challenges and requirements

10 February 2021
Tomasz BEGER
This article is going to offer insight into some of the latest changes brought by the Regulation of the Minister of Finance, Funds and Regional Policy of 18 December 2020 amending the regulation on transfer pricing information in personal income tax and corporate income tax to be reported in TPR-P and TPR-C forms. The said provisions have been in force since 1 January 2021 and apply to transfer pricing reporting for a tax year commencing after 31 December 2019.

More changes in transfer pricing are coming

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.

Pages

Blog - Autorzy

Anna MAJ (1)
Ewa PYTEL (1)