Have you heard of the “six degrees of separation” theory? It’s a concept that assumes that, as a resident of Earth, you can meet any other person in the world with just six or fewer mutual connections between you and that person, whether through acquaintances, friends, or their family members. What does this theory have…
In the dynamic business world, planning of settlement between related parties is becoming an essential part of groups’ business strategy. Changes in the market affect the development of new technologies, products and services. They determine the activities of companies in achieving economic benefits and competitive advantages. Well planned settlements are the basis for business success,…
An APA (advance pricing arrangement) is an agreement on the transfer price applied in transactions between related parties, concluded between a taxpayer and the Head of the National Revenue Administration. The APA takes the form of an administrative decision and constitutes a confirmation by the tax authority of the arm’s length principle of settlements between…
When we talk about transfer pricing, we’re definitely thinking about transferring funds. And probably abroad. Most likely to a tax haven. If this was your first association upon seeing the title, make sure to read this article to the end. We’ll demystify transfer pricing, show you what it really is, and explain why it’s worth…
Recently, there has been a noticeable increase in interest in ESG topics. This is due to two reasons: the increase in stakeholder interest in off-balance sheet activities and the extension of the ESG reporting obligation (so far, the ESG issue in Poland concerned about 150 entities, but due to the change in the rules, from…
The deadline for submitting the CBC notification (CBC-P) for 2023 to the Head of KAS is coming soon – 31 March 2024 (for all entities whose financial year matches the calendar year). This obligation covers entities belonging to capital groups that are subject to the CBC-R. Who? The obligation applies to entities (which are not…
Why is it important to accurately determine the functional profile? The functional profile should be understood primarily as the role of an entity in a transaction. It depends on its business activity in the market or in the transaction (e.g. manufacturer, distributor) and its level of involvement in the transaction in terms of functions performed,…
Recently, intangible services have been one of the key areas reviewed during tax audits. As statistics made available to us by the Ministry of Finance show, service transactions account for almost 30% of all transactions reported by taxpayers in 2020-2021 in the TPR form, of which as much as 10% are intangible services. Intangible services…
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,…