Not every adjustment to transaction prices is a transfer pricing adjustment Related parties often apply transaction price adjustments in their settlements. The so-called contractual adjustment and transfer pricing adjustment within the meaning of Article 11e of the CIT Act are perceived differently in terms of CIT. Choosing the right category in a particular case raises…
In recent days, Artur Soboń – Deputy Minister of Finance – announced changes in CIT aimed at simplifications and solutions aligned with the current economic situation. The Ministry of Finance proposes simplified rules concerning the documentation of tax haven transactions and increasing the related documentation thresholds (currently at PLN 100,000 for direct tax haven transactions…
Today we wish to remind you of how important it is to properly determine the functional profile for TP purposes. The functional profile results from the entity’s involvement in the transaction: the functions performed, the assets involved and the level of risk exposure. Importantly, the functional profile should support the management of the assigned risk…
