At the end of last year, the outcome of the Amazon group’s tax dispute was widely reported in the media. The judgment relates to transfer pricing issues and the possibility of invoking the OECD guidelines. Tax benefits EU Competition Commissioner Margrethe Vestager pointed out that Luxembourg granted Amazon illegal tax benefits. As a result, almost…
On 21 December 2023, the CJEU handed down a long-awaited judgment on the VAT taxation of board members’ remuneration[1]. The judgment concerned a member of the board of directors of several public limited companies under Luxembourg law who, by virtue of his position, participates, inter alia, in decisions regarding the risk policy, accounting and strategy…
This year, when selling food or beverages in single-use packaging to consumers, a SUP fee they must be charged (PLN 0.20 or 0.25). The new obligation has come as a surprise to many businesses, as there is no guidance from the Ministry of Climate or the Ministry of Finance. For instance, it is not entirely…
The new Notice of the Minister of Finance on the announcement of the type of base interest rate and margin for transfer pricing (safe harbor for financial transactions) has been published! Conditions for safe harbor in financial transactions The Finance Minister has updated the conditions authorizing the use of safe harbor simplification for financial transactions.…
On July 3, 2023, a parliamentary interpellation was submitted to the Minister of Finance regarding the obligation of spouses entering into business transactions between themselves to prepare transfer pricing documentation. The authors of the interpellation pointed out that according to the CIT Act and the PIT Act, transfer pricing documentation and reporting obligations also apply…
Many companies in capital groups make an annual price adjustment in transactions with a related company after the end of the year, in order to achieve a target level of profitability. The question arises – does such an adjustment affect VAT settlements and how should it be documented? Although the subject of transfer pricing adjustments…
We recently wrote on our blog about intangible assets and accounting for them. In this post, we would like to highlight another intangible asset issue, namely Hard-to-Value Intangibles (abbreviated HTVI). The term itself and the word “hard” used in it signals to us the problems that can be encountered when making transactions involving intangible assets…
The Court of Justice of the European Union (CJEU) confirmed in its judgment of 16 November 2023 (C-366/22 Viterra Hungary) that it is not only the objective characteristics and properties of the goods that affect their classification, but also the processing or treatment process and their intended use. What does the case involve? The case…
Although the deadlines for filing the transfer pricing information (TPR) form for 2022 are to be extended by 3 additional months, many taxpayers have decided to file it by the original deadline. In addition to the information on these transactions, however, there are a few additional issues that should not be forgotten when filling out…
One of the key elements of transfer pricing documentation is a transfer pricing analysis. It can be prepared in the form of a benchmarking analysis or in the form of a compliance analysis. The transfer pricing analysis must include (with justification for selection): transfer pricing verification method; selected party or transaction to be investigated; a…