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…
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…
1. Is it true that the draft envisages taxing photovoltaic farms on all components, including PV panels? Not really. The draft explicitly refers to wind and nuclear power plants as facilities to be taxed only on the construction parts. It is controversial that photovoltaic power plants are not mentioned, since they are a common type…
After a series of favorable rulings for CIT taxpayers by provincial administrative courts in cases concerning CIT exemptions for compensation granted to energy-intensive sectors, the Supreme Administrative Court [NSA] has issued a ruling with reference II FSK 397/24, which broke the previous line of jurisprudence. Previous case law In the judgments issued so far, provincial…
1. How will transformer stations be treated in the draft regulatory changes? Will they have to be taxed with property tax starting in 2025? In the draft amendments to the Law on Local Taxes and Fees presented by the Ministry of Finance, there is no direct mention of transformer stations. However, this does not mean…