A significant number of regulatory changes and a growing number of audits by tax authorities make the topic of transfer pricing increasingly relevant.
Transfer pricing is also heavily influenced by extraordinary events and crises, like the COVID-19 pandemic and the war in Ukraine. Importantly, tax authorities often require much more commitment from related parties to properly set the terms of transactions than from third parties. Unlike third entities, group entities have a statutory obligation to establish and verify the terms of their transactions at arm’s length.
Our review includes a collection of selected court rulings from 2022. It will help you better understand the problems and risks involved in the area of transfer pricing.
We hope that our study will prove useful for anyone seeking information on transfer pricing.
Magdalena Marciniak
Partner | Tax adviser | Head of the Transfer Pricing Practice E: magdalena.marciniak@mddp.pl T: (+48) 665 746 360