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…
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…
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…