Transfer pricing documentation within multinational capital groups has become an invaluable tool not only in the context of transfer pricing verification, but also in relation to other taxes, including withholding tax (WHT). In Poland, tax authorities are increasingly referring to group documentation, namely the Master File, during WHT audits.
Transfer pricing benchmarks under judicial scrutiny. Key insights from recent international case law and their implications for taxpayers.
Deferred payments in related-party transactions may undermine arm’s length conditions and lead to income adjustments by tax authorities
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.