What is Local File documentation? Transfer pricing documentation is a legally required document focused on intra-group transactions. You must prepare the Local File documentation when engaging in controlled transactions with related entities. Typically, it is required when the value of such transactions exceeds the financial thresholds set by regulations within the tax year. The statutory…
Admittedly, this is only to apply to property tax returns and will require taxpayers to submit a declaration to the tax authorities, but it is worth appreciating the opportunity provided by the latest draft amendment to the Local Taxes and Fees Act. Why such an opportunity? The circumstance is related to the new definitions of…
The year 2024 has not introduced any major changes to transfer pricing regulations. However, related parties must still carefully comply with documentation and reporting obligations for intra-group transactions made in 2023. The process begins with identifying relationships as defined by transfer pricing regulations. The next step is determining whether the transactions qualify as controlled transactions…
The Ministry of Finance, following the example of previous regulations issued during the pandemic and in support of victims of the armed conflict in Ukraine, prepared a regulation introducing a temporary 0% VAT rate for free-of-charge supplies of goods and services aimed at supporting flood victims. The possible legal path of a regulation allowing for…
Transfer Pricing: who has documentation and reporting obligations? If: you are a taxable person (subject to corporate income tax or personal income tax), and in 2023, you engaged in transactions with related parties, and the value of these transactions exceeded the statutory thresholds in 2023, then you need to determine your transfer pricing obligations…
Not long ago, we informed about an unfavourable stance of the Director of the National Fiscal Information (KIS) on the rules of taxation of beneficiaries of a foundation established jointly by members of the closest family (e.g. spouses). The Director of KIS has a modified approach to the manner of determining the proportion of property…
There is an ongoing wait for the new definitions of building and structure for property tax purposes to come into effect from 2025, which is just a few months away. One group of taxpayers for whom the announced regulations will be relevant are owners of various types of tent structures, such as tent covers, inflatable…
Aim of the SME package: simplify cross-border VAT settlements Currently, traders doing business in different European Union (EU) countries where they are not established must, in many cases, register for VAT. This requirement involves filing VAT returns in each EU country where VAT is due. This process is particularly burdensome for small and medium-sized enterprises…
Supreme Administrative Court draws attention to the economic nature of land sale transactions The Supreme Administrative Court (NSA), in a ruling of 23 August 2024 (ref. I FSK 1670/20), again addressed the issue of the application of the VAT exemption to the sale of undeveloped land. The ruling is in line with previous judgments of…
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)…