Transfer pricing audit – how to limit tax risk in a capital group
A transfer pricing audit helps identify tax risks, organise intra-group settlements and better prepare a company for potential tax audits.
Public CbC-R in Poland. How to Protect Sensitive Information from Disclosure?
The Public CbC-R in Poland, effective from 2026, introduces the obligation for companies to publicly disclose their financial and tax data, with the option to protect sensitive information.
Exemption of dividends from withholding tax without the requirement of beneficial ownership status – significance of the Head of the National Tax Information Service’s ruling
The condition of beneficial ownership has remained one of the key issues in withholding tax for many years, particularly in the context of applying exemptions provided for in the CIT Act. The legislator explicitly made the exemption from withholding tax on royalties and interest conditional upon beneficial ownership. In practice, however, tax authorities tend to…
Personal links and the exemption from transfer pricing documentation (article 11n(5) of the Polish Corporate Income Tax Act)
Personal links and the TP documentation exemption – when Article 11n(5) of the CIT Act applies and what risks arise from KIS practice and court case law.
Companies with a shifted financial year – transfer pricing obligations
Companies with a shifted financial year – check your transfer pricing obligations. TP audit, documentation, TPR, and Master File, including for foreign entities.
CbC-P – who is required to file and when in 2026?
The deadline for CBC-P for 2025 is 31 March 2026; check who is required to file, what data must be reported, and the applicable sanctions.
Transfer pricing adjustments – a tool for restoring the arm’s length nature of controlled transactions
Transfer pricing adjustments as a tool for restoring arm’s length conditions. Legal requirements, tax risks, VAT implications and Polish practice.
“Total working time” in R&D tax relief – how should it understood?
Eligible costs under the research and development (R&D) tax relief include, among others, expenses incurred on the remuneration of employees performing R&D activities. These expenses may be deducted to the extent that the time devoted to R&D activities remains in proportion to the employee’s total working time in a given month. Moreover, the concept of…
Transfer pricing adjustments – global challenges, domestic obligations
Transfer pricing adjustments in Poland and abroad. The arm’s length principle, OECD guidelines, tax conditions, case law, and the risk of double taxation.
Year-end in transfer pricing – obligations, risks and key actions for 2025/2026
Year-End in Transfer Pricing: Key Documentation Obligations and Actions for 2025/2026 to Minimise Tax Risk.