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Polish Deal and transfer prices – the scope of planned changes

The bill introducing a broad package of changes to taxation under the so-called Polish Deal includes some novelties in the area of transfer prices. We recommend familiarizing with the upcoming changes already now. Some of the changes are intended to simplify regulations and these will lead to lifting some of the documentation requirements. Other changes cause an increased risk involved in documenting transactions with related parties.

ALERT PODATKOWY 2021 / 08 / 23

“Polski Ład” [“The Polish Deal”] – major changes planned to corporate income tax (CIT)

Last week, a bill of amendment to the Personal Income Tax Act, the Corporate Income Tax Act and some other acts was submitted for social consultations. The bill results from the social and economic plan announced by the Government, known as “the Polish Deal”.

TAX ALERT 2021 / 08 / 05

Draft general ruling on a definition of a uniform controlled transaction

On 12 July 2021, a draft general ruling was published on the website of the Ministry of Finance, Funds and Regional Policy (of 30 June 2021). The ruling contains a definition of a uniform controlled transaction.

TAX ALERT 2021 / 07 / 20

TP deadlines likely to be extended by 3 months

Deadlines for compliance with the transfer pricing obligations are likely to be extended again. On 25 February 2021, the Transfer Pricing and Valuation Department informed that the Public Finance Commission of the Sejm adopted an adjustment to the bill of amendment of the excise duty act and some other acts (form 860). The deadlines for […]

ALERT PODATKOWY 2021 / 03 / 24

Presumption and due diligence in transfer pricing – tax consultations

On 5 March 2021, the Ministry of Finance opened tax consultations concerning a document entitled “Explanations of Transfer Prices No 4 – presumption and due diligence referred to in Art. 11o(1b) of the CIT Act and Art. 23za(1b) of the PIT Act.”.

TAX ALERT 2021 / 03 / 24

2021 novelties in transfer pricing: transactions with tax havens, changes to TPR and reports on implementation of tax strategies

Transfer prices have recently been a topic of much interest for tax authorities, and the legislator keeps amending, expanding and elaborating on the existing regulations. Starting from 1 January 2021, taxpayers must adopt new rules for transactions with tax havens, TPR filings and publication of tax strategy reports.

TAX ALERT 2021 / 01 / 13

Transfer pricing changes take effect

In one of our previous newsletters we informed about the proposed changes to transfer prices, including the COVID-19-related simplifications.
These were introduced upon the Act of 28 November 2020 amending the personal income tax act, corporate income tax act, flat rate income tax on selected earnings of natural persons and other selected acts (Journal of Laws item 2123), promulgated on 30 November 2020.

TAX ALERT 2020 / 12 / 09

Deadline for preparation of TP documentation

The deadline for submission of the transfer pricing information and the statement on preparation of a local file ends on 31 December 2020 for those entities whose tax year overlaps with the calendar year.

Transfer Prices for 2019 2020 / 10 / 08

SHIELD 4.0 – changes to tax regulations

Last Friday, on 19 June 2020, the Sejm passed the Act on subsidies to interest on bank loans provided to COVID-19-affected entrepreneurs and on simplified procedure for approval of a composition in connection with COVID-19 (hereinafter “the Act”), also known as Shield 4.0. The Act also amends tax regulations.

TAX ALERT 2020 / 06 / 23

Amendment to income tax, VAT and the Tax Code adopted by the Sejm

On 6 May 2020, the Sejm passed an amendment to the Corporate Income Tax Act (CIT Act), the Personal Income Tax Act (PIT Act), the Flat-rate Income Tax and Tax on Goods and Services Act (the VAT Act) as well as the Tax Code. The bill will now be considered by the Senate, at the moment it is examined by the Budget and Public Finance Committee.

TAX ALERT 2020 / 05 / 15

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