Related parties – what exactly are they in Polish transfer pricing regulations?

Related parties are required to prepare transfer pricing documentation. This concept is crucial for determining documentation obligations, so it’s important to familiarize yourself with it in detail!   Related parties in Polish income tax laws The definition of related parties is explicitly outlined in income tax laws. To classify entities as related parties, one must…

Master file – Polish transfer pricing regulations

In certain situations, related entities are required to prepare a master file for transfer pricing documentation. Master file – who is required to prepare it? The master file is a component of transfer pricing documentation that provides information about the entire group of related entities to which the taxpayer belongs. If you want to learn…

Transfer pricing documentation – penalties and sanctions

A taxpayer who fails to prepare transfer pricing documentation, despite being required to do so, faces various penalties and sanctions arising both from tax law provisions and the fiscal penal code. Penalties and sanctions in transfer pricing A taxpayer who has failed to fulfill the obligations arising from transfer pricing regulations may face the following…

Who is required to have transfer pricing documentation?

The documentation obligation regarding transfer pricing applies to both PIT (personal income tax) and CIT (corporate income tax) taxpayers. According to regulations, related entities are required to prepare local transfer pricing documentation for the tax year to demonstrate that transactions were concluded on terms that would have been agreed upon between unrelated parties.  Definition of…

Transfer pricing control

The practice of polish tax authorities in recent years indicates a significant increase in the number of conducted audits regarding controlled transactions. The actions taken are becoming increasingly effective, so it’s worth being prepared for them. How many audits have tax authorities conducted recently, and how do the verification activities proceed? You’ll find out all…

The purpose of transfer pricing audit

The purpose of transfer pricing audits is to enhance tax security and optimize processes related to settlements between related entities.  The main task of the audit procedure is to determine whether challenges related to transfer pricing are managed correctly and to propose mechanisms to reduce tax risks associated with subsequent tax years.  The transfer pricing…

Comparative data analysis

According to the provisions of the Income Tax Acts, local transfer pricing documentation generally should include a comparative analysis or a conformity analysis. What should a properly prepared analysis contain? We clarify all doubts in the following article.  Comparative analysis – what is it?  Comparative data analysis is commonly known as “benchmarking.” Its essence lies…

Declaration on preparation of transfer pricing documentation

From January 1, 2019 taxpayers are required to submit an electronic statement on the preparation of transfer pricing documentation. For taxpayers whose tax year is a calendar year, the deadline for submitting the declaration for 2019 is December 31, 2020.

TPR – who and when have to report on transfer prices for 2019?

The new reality associated with the emergence of the coronavirus epidemic has brought many changes, also in the area of transfer pricing obligations. Check if you are required to provide information about transfer prices and when the new deadline for submitting this form to the tax office expires.

Benchmark study

Partnership

ABC transfer pricing documentation

Are you wondering what transfer prices are and what obligations are associated with them? What exactly is involved in preparing transfer pricing documentation? All doubts are clarified in the article below. Basic Concepts in Transfer Pricing Transfer Price Documentation obligations are based on the concept of transfer pricing. According to the statutory definition, this means…

A new model statement on having transfer pricing documentation

A new model statement on having transfer pricing documentation English version

Transfer prices 2018

English version here

Local file guide

On 1 January 2019 new transfer pricing regulations came into force. Get familiar with the changes and see which regulations apply to transactions carried out in 2018. Local file – transactional thresholds Prior to the changes, the taxpayers were obliged to prepare documentation if their revenues or costs in the preceding tax year exceeded EUR…

Transfer pricing audit

The main objective of the transfer pricing audit is to reduce tax risks and optimize business processes. The transfer pricing audit is addressed to entities who are required to prepare tax documentation and entities who do not have such an obligation – since tax penalties related to non-market price (surcharge at the rate of 10%)…

Transfer pricing policy

The transfer pricing policy is a set of consistent and transparent rules on how to carry out transactions (esp. how to set a price) between related entities. The transfer pricing policy covers the principles that are followed by related entities in the process of determining the terms of the transaction. It therefore differs much from…