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…
When trying to complete the TPR form, it is good to remember what the primary purpose of this reporting is. The Ministry of Finance explicitly indicates that “the purpose of TPR reporting is for the tax administration to gather selected information for the analysis of the risk of understatement of taxable income in the field…
In 2023, the deadlines for completing transfer pricing obligations for 2022 have been shortened. The starting point for fulfillment of TP obligations is reliable local documentation (Local File). Deadline for fulfillment of obligations For taxpayers whose tax year coincides with the calendar year, the deadline for Local File for 2022 is October 31, 2023. Admittedly,…
The first-ever scent trademark has been registered in the European Union. Moreover, as much as 79% of consumers prefer to buy products with “eco” trademarks. The appearance of the Apple store is registered as a trademark. A patent claim must be written in the form of a single sentence, and this rule applies worldwide… All…
Identifying the links between parties to a transaction is not only crucial, but also one of the first things a taxpayer should do before proceeding with transfer pricing documentation and reporting obligations. Given the high volatility and uncertainty of the tax laws, it is worthwhile to verify well in advance that for a given year…
Safe harbour is a mechanism to reduce documentation and transfer pricing reporting obligations provided that the taxpayer meets several statutory requirements. Once such conditions are met, the taxpayer is supposed to gain certainty as to the arm’s length nature of the price applied in the transaction carried out. However, is compliance with the conditions sufficient…