Establishment a permanent establishment and transfer pricing obligations

Establishment a permanent establishment and transfer pricing obligations Conducting business in another country may lead to the establishment of a permanent establishment (PE), which carries with it a number of tax obligations, including transfer pricing obligations. Transfer pricing regulations treat a company and its permanent establishment as related parties. In addition, the legislature includes, among…

Who submits the TPR form after a merger?

The dynamically changing economic situation, continuous development of competition in most industries and the increase in costs constitute a quite challenge for companies. In order to maintain or improve their market position or minimize operating costs, capital groups decide, for example, to merge companies. Although the merger process itself is regulated by the provisions of…

Planning, rather than mere compliance, is the essence of transfer pricing

For most taxpayers, transfer pricing is associated with numerous and complex formal requirements that must be met within a specified deadline, under the threat of escalating and increasingly severe sanctions. But what if we approached the issue of market conformity of transactions differently? The established pattern Among the majority of taxpayers, we often observe the…

Changes in the base interest rate and margins – announcement regarding transfer pricing!

The new Notice of the Minister of Finance on the announcement of the type of base interest rate and margin for transfer pricing (safe harbor for financial transactions) has been published! Conditions for safe harbor in financial transactions The Finance Minister has updated the conditions authorizing the use of safe harbor simplification for financial transactions.…

Are transactions between spouses subject to transfer pricing obligations?

On July 3, 2023, a parliamentary interpellation was submitted to the Minister of Finance regarding the obligation of spouses entering into business transactions between themselves to prepare transfer pricing documentation. The authors of the interpellation pointed out that according to the CIT Act and the PIT Act, transfer pricing documentation and reporting obligations also apply…