What consequences may arise from an informal group decision?
Informal group decision and transfer pricing: risk, lack of remuneration and tax authority approach in case law
Informal group decision and transfer pricing: risk, lack of remuneration and tax authority approach in case law
A transfer pricing audit helps identify tax risks, organise intra-group settlements and better prepare a company for potential tax audits.
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.
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 – check your transfer pricing obligations. TP audit, documentation, TPR, and Master File, including for foreign entities.
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 as a tool for restoring arm’s length conditions. Legal requirements, tax risks, VAT implications and Polish practice.
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: Key Documentation Obligations and Actions for 2025/2026 to Minimise Tax Risk.
How does the Master File impact withholding tax (WHT) in Poland? Review the key risks, obligations, and actions that a Polish company within an international group should consider.