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…
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…
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…
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…
One of the types of controlled transactions that can be carried out between related parties are capital transactions, including those involving share capital increases and surcharges. In both cases, the purpose is to recapitalize the company and finance its operations, while the effects that arise on transfer pricing grounds are different. In the event of…
The deadline for submitting the 2022 TPR form (for taxpayers whose tax year coincides with the calendar year) was supposed to be 30 November, less than a month away. It should have been. The Ministry of Finance’s announcements suggest that the deadline will be extended to the end of February 2024. Unfortunately, we do not…