Law & Numbers - News Tax

New transfer pricing regulations

14.12.2015 (Poland)

Polish taxpayers when preparing the annual income tax returns for 2016 shall take into account a number of new transfer pricing (TP) documentation requirements. Under the new regulations, some taxpayers will be obliged to prepare more extensive TP documentation (to that currently required), which will include mandatory local benchmarking analyses.

Polish taxpayers when preparing the annual income tax returns for 2016 shall take into account a number of new transfer pricing (TP) documentation requirements. Under the new regulations, some taxpayers will be obliged to prepare more extensive TP documentation (to that currently required), which will include mandatory local benchmarking analyses. Additionally the deadline for preparing TP documentation will be brought into line with the annual tax return deadline (currently no such deadline is set). Under amended law some multinational enterprises will be obliged to prepare a master file describing operations of the group. In addition, the largest Polish multinational enterprises (with consolidated income exceeding EUR 750 million) will be subject to Country-by- Country (CBC) reporting requirements. These changes are in line with OECD recent actions described in the BEPS project. Generally the majority of the draft amendments introduce additional TP documentation burdens on Polish groups and taxpayers. However, there are also TP documentation exemptions proposed for small taxpayers (i.e. where neither their costs, nor income exceed EUR 2 million).

For more information please contact:

Agnieszka Wierzbicka
wierzbicka@rklegal.pl
+48 22 292 03 59

Karol Kozłowski
kozlowski@rklegal.pl
+48 22 292 03 15







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