Master File (group transfer pricing documentation) – what is it and who is required to prepare it?

Master File (group transfer pricing documentation) – what is it and who is required to prepare it?

For many taxpayers, transfer pricing (TP) compliance forms a crucial part of their annual tax closing procedures. The period from October to December is typically intensive –preparing the Local File and submitting the TPR-C form requires precision and coordination across multiple departments. Alongside local documentation, the Master File – the group-level transfer pricing documentation –…

Intra-group settlements under scrutiny by the CJEU - what does the Weatherford ruling mean for intra-group service acquisitions?

Intra-group settlements under scrutiny by the CJEU – what does the Weatherford ruling mean for intra-group service acquisitions?

In the first article of our TP & VAT series (link: https://www.mddp.pl/intra-group-settlements-under-the-scrutiny-of-the-cjeu/ ), we outlined the general background to recent rulings by the Court of Justice of the European Union (CJEU) in this area. Today, we delve deeper into the topic by analysing the Weatherford judgment (Case C-527/23), which carries significant implications for the interpretation…

Does a gratuitous guarantee under Estonian CIT mean no transfer pricing obligations?

Does a gratuitous guarantee granted to a taxpayer subject to Estonian CIT by a related entity give rise to a transfer pricing documentation obligation? According to DKIS [1] – yes – if the value of the guarantee exceeds the threshold of PLN 10 million, the taxpayer will be required to prepare transfer pricing documentation.  …

General partnership and transfer pricing in 2025 – Local file documentation, CIT-15J and TP obligations

General partnership and transfer pricing in 2025 – Local file documentation, CIT-15J and TP obligations

The arm’s length principle applies to all entities conducting transactions with related parties and to all transactions – regardless their value. Even if a transaction does not exceed the documentation thresholds and does not trigger the obligation to prepare local transfer pricing documentation, it is not exempt from complying with the arm’s length principle. Transfer…

Intra-group settlements under the scrutiny of the CJEU – key issues in transfer pricing and VAT

Intra-group settlements under the scrutiny of the CJEU – key issues in transfer pricing and VAT

The issue of intra-group transactions in the context of value-added tax (VAT) is increasingly attracting the attention of the Court of Justice of the European Union (CJEU). Recent cases underscore the importance of delineating the boundaries between direct tax (CIT) and indirect tax (VAT) regulations, as well as the significant practical implications that transfer pricing…

OECD Amount B – what does the new mechanism mean for businesses?

OECD Amount B – what does the new mechanism mean for businesses?

The Organisation for Economic Co-operation and Development (OECD) plays a pivotal role in shaping the global tax landscape, particularly in the context of the digital economy. Its objective is to establish a more equitable and predictable international tax framework that addresses the challenges posed by globalization and the operations of multinational enterprises. In response to…

Customs duties and transfer pricing – how to integrate tax strategies within an international supply chain?

Customs duties and transfer pricing – how to integrate tax strategies within an international supply chain?

Modern companies operating in international markets face the challenge of aligning customs and transfer pricing policies. A lack of consistency between these areas can lead to significant tax, operational and financial risks. For this reason, close cooperation between customs and transfer pricing departments is essential – only through collaboration can risks be effectively managed, and…

How to determine the value of a consortium transaction and when transfer pricing documentation obligations arise

How to determine the value of a consortium transaction and when transfer pricing documentation obligations arise

Consortia are a commonly selected form of cooperation for the execution of large-scale projects, particularly in the construction, engineering, and financial sectors. The formation of a consortium typically serves the purpose of jointly executing a specific commercial undertaking which, due to its financial, logistical, technical, or organisational complexity, exceeds the capacity of a single entity.…

Licencja i wycena znaku towarowego – opłaty, DEMPE, metody i praktyka

Licencja i wycena znaku towarowego – opłaty, DEMPE, metody i praktyka

Znaczenie znaku towarowego w budowaniu wartości firmy Znak towarowy to chronione prawem oznaczenie, które identyfikuje produkt lub usługę jako pochodzącą z określonego źródła. Znak towarowy to jeden z kluczowych elementów budujących tożsamość przedsiębiorstwa na rynku – pozwala odróżnić towary lub usługi jednego przedsiębiorcy od innych. Może przyjmować różne formy – od nazwy, logo, przez kształt…

Transfer pricing policy in the context of customs regulations, ESG, and the Green Deal – how to build it effectively?

In recent years, transfer pricing policy has evolved from a purely tax-focused document into a key component of broader compliance strategy. Regulatory changes – both at national and EU levels – now require transfer pricing (TP) policies to address not only tax regulations but also customs matters, environmental concerns, and corporate governance (ESG) considerations. Why…