Transfer Pricing: obligations await! The holidays are coming to an end, and as children head back to school, businesses must also turn their attention to fulfilling transfer pricing obligations for the 2023 tax year. Key deadlines are approaching for: Local transfer pricing documentation (Local File) Transfer pricing information (TPR) Group transfer pricing documentation (Master File)…
What is the call-off stock procedure and what is its application? In Intra-Community trade, as a rule, the movement of goods by a taxpayer constitutes an Intra-Community acquisition of goods. This means that the taxpayer carrying out such a movement is required to register for VAT purposes in the country of the buyer and account…
Transfer prices can impact the amount of income taxed in different countries. To ensure compliance, set these prices at the same level that unrelated parties would use in their transactions. Here’s how to do it. Various transfer pricing verification methods are used to assess the prices set between related parties. There are five basic methods,…
On July 25, 2024, the Director of the National Tax Information issued an individual tax ruling[1] confirming the right to recognize a fee for the termination of a real estate sales contract as a tax deductible cost. What was the case about? In the case under review, a real estate development company entered into a…
What is a benefit test? The benefit test is an analysis that confirms the following: the purchased intangible services have indeed been performed, the recipient derives benefits from the purchase that contribute to their income, the purchase of services is business rational. Who does it apply to? The benefit test applies to all group entities…
The current position of the tax authorities confirms that people immigrating to Poland permanently who do not have a Pole’s Card on the date of their move – either because they have not applied for it before or have already obtained a permanent residence permit – cannot benefit from the PIT exemption. The exemption known…
Authorities around the world are increasingly scrutinizing the nature of intra-group loans We observe that tax authorities and courts are more frequently recharacterizing loan transactions, challenging their substance and arm’s length nature. Authorities are now examining not only the market terms of the interest rate but also the underlying substance of the transaction. They are…
At the end of July, a further version of the draft amendment to the DRS legislation also addressed tax issues. Although it takes into account a significant part of the postulates made by future participants of the system, the solutions proposed in it as to the settlement of VAT in the bail system opens new…
International groups often prepare global benchmarks, which are used by entities in different jurisdictions for local transfer pricing documentation. This approach ensures consistency in global transfer pricing policies and helps reduce the local costs associated with transfer pricing obligations. But is there a universal benchmarking that guarantees the defensibility of transaction arm’s length conditions in…
Increasing globalization is connected with not only threats but also with numerous opportunities. Multinational companies create innovations and know-how, which can be shared with other group entities or transferred to affiliates in other countries. During the transfer of intangible assets, it is crucial to analyze the pros and cons of the planned relocation. Remember that…