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.
Discover the latest Supreme Administrative Court (NSA) ruling and individual tax interpretation regarding the exemption from local transfer pricing documentation under Article 11n(5) CIT.
Financial transactions in transfer pricing: what to watch out for to avoid mistakes and penalties? We invite you to read the article by MDDP experts.
Learn how to carry out a professional business valuation. Discover the methods, stages and key factors that influence your company’s value.
Local File 2024: discover why the reliable preparation of transfer pricing documentation and consistency with the Transfer Pricing Regulation (TPR) are essential for tax security.
Why TP obligations for 2024 matter for businesses The upcoming autumn marks the need to fulfil transfer pricing obligations for 2024. Businesses are required to prepare the Local Transfer Pricing Documentation (Local File) for 2024 and keep in mind the upcoming deadlines relating to the TPR form and the Group Transfer Pricing Documentation (Master File).…
TPR (Transfer Pricing Report) is a key obligation for taxpayers carrying out transactions with related entities. Its purpose is to provide the tax authorities with essential information about transactions, including the reported profitability. TPR reporting is not merely a formality – it is a tool that enables quick insight into transactions and facilitates the selection…
“Debt analysis,” “debt capacity,” “analysis of debt servicing ability” – many terms exist in the world of transfer pricing, but they all refer to the same issue. It is no longer a secret that tax authorities, when examining financial transactions, check not only the level of applied interest rates but also other conditions, including the…
Continuing the TP and VAT series, in which we discuss the most important cases regarding intra-group settlements (see: Intra-group settlements under the scrutiny of the CJEU – key issues in transfer pricing and VAT), this time we are looking at the Arcomet case (C-726/23), which introduces a new perspective on a well-known topic. The issue…
Transfer pricing analysis forms the backbone of the Local File and the TPR (Transfer Pricing Report) form. Find out how to avoid income reassessments and prepare an analysis robust enough to pass a customs and tax audit. Introduction At first glance, everything appears to be in order. The company’s results fall within the range. Documentation…