Will your benchmark stand up to scrutiny by the tax authority? Key takeaways from the recent foreign case law.

Transfer pricing benchmarks under judicial scrutiny. Key insights from recent international case law and their implications for taxpayers.

Deferred payment between related parties – what consequences does it entail?

Deferred payments in related-party transactions may undermine arm’s length conditions and lead to income adjustments by tax authorities

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

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.

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.

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.