MDDP on Polish Taxes | 2020 as the year of transfer pricing challenges – an overview of Polish transfer pricing obligations for FY 2020 and FY 2021

FY 2020 was undoubtedly marked by uncertainty. Global COVID-19 pandemic triggered many challenges globally and in Poland. It also had a direct impact on settlements with related entities.

The webinar will address key TP obligations for FY 2020 and FY 2021 in Poland. We will compare them with the three-tiered approach to TP documentation introduced in the OECD Guidelines. New obligations will be highlighted regarding transfer pricing documentation for FY 2021 for transactions with tax haven entities. In addition, we will outline the impact of the COVID-19 pandemic on transfer pricing obligations for FY 2020, with particular emphasis on the approach to the update of benchmarking analysis.

Overview of transfer pricing requirements in Poland for FY 2020:

• which TP obligations should be met for FY 2020?
• are there any special local requirements for Local File and Master File in Poland?
• what deadlines are binding?
• how to approach the update of benchmarking analysis during COVID-19?
• safe harbour regulations – how to apply them in Poland, especially for low value adding services?
• TP adjustments mechanism – how to ensure a safe tax position?

TP-R form – special declaration for reporting the most important information for intragroup transactions:

• what information should be reported?
• TP-R form FY 2019 vs FY 2020 – changes in the new version of the TPR form.

New Polish TP requirements for FY 2021 on tax havens:

• controversial new TP documentation obligations for transactions made with unrelated business partners: how to ensure due diligence of Polish taxpayers?