Establishment a permanent establishment and transfer pricing obligations Conducting business in another country may lead to the establishment of a permanent establishment (PE), which carries with it a number of tax obligations, including transfer pricing obligations. Transfer pricing regulations treat a company and its permanent establishment as related parties. In addition, the legislature includes, among…
Are you submitting a TPR? – Don’t forget about complimentary services There are only 3 days left to file the TPR form for taxpayers whose tax year matches the calendar year. When identifying related party transactions that are subject to reporting, remember that they don’t just involve typical commercial or financial transactions. In today’s post,…
When planning to submit transfer pricing information (hereinafter: TPR) for the tax year beginning after December 31, 2021, it is important to remember that compared to the previous tax year, there has been a change in the existing form and scope of data reported in this declaration. The Ministry of Finance has decided to abandon…
On January 18, 2024, the Advocate General of the Court of Justice of the European Union issued an opinion on the customs classification of prefabricated buildings. The case focuses on whether these buildings, which are mainly made of plastics, should be classified as “prefabricated buildings” under tariff heading 9406 or as “other articles of plastics”…
The dynamically changing economic situation, continuous development of competition in most industries and the increase in costs constitute a quite challenge for companies. In order to maintain or improve their market position or minimize operating costs, capital groups decide, for example, to merge companies. Although the merger process itself is regulated by the provisions of…
For most taxpayers, transfer pricing is associated with numerous and complex formal requirements that must be met within a specified deadline, under the threat of escalating and increasingly severe sanctions. But what if we approached the issue of market conformity of transactions differently? The established pattern Among the majority of taxpayers, we often observe the…
Despite the festive period and personnel changes in the structures of the Ministry of Finance, work on National e-Invoicing System (KSeF) and the topics related to its implementation is not slowing down, as exemplified by the Ordinance of the Minister of Finance of 29 December 2023 amending the Ordinance on the detailed scope of data…
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…
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.…