We are pleased to present the second edition of our review of court rulings in the field of transfer pricing. This time we have analyzed the decisions from 2023.
Last year, we observed numerous significant rulings that influenced the authorities’ approach to transfer pricing issues. Most of the cases resolved by the courts in 2023 dealt with entirely different matters compared to the previous year.
The trend of intensified transfer pricing controls aligns with the increasing competence of tax authorities, impacting the precise analysis of controlled transactions. The evolution of regulations and the expectations of authorities are evident in recent court rulings.
We stress the importance of adjusting transfer pricing documentation and analyses to evolving business and regulatory conditions, ideally before engaging in a particular transaction. In 2023, taxpayers grappled with challenges stemming from inflation and geopolitical shifts, which also influence the determination of transaction terms and documentation obligations.
Our aim is not merely to present the rulings but also to aid in developing practical solutions and strategies for minimizing risks. The review incorporates comments from our experts to steer you towards effective management of the transfer pricing domain.
In our review, we concentrate on specific court rulings from 2023 that offer valuable insights and tips concerning risk in tax audits and compliance with transfer pricing obligations.
Magdalena Marciniak
Partner | Tax Advisor E: magdalena.marciniak@mddp.pl T: (+48) 665 746 360