Who signs the TPR form and the Local File declaration? Rules for management boards and proxies, and changes to TPR signing requirements for FY2026.
The exemption from transfer pricing analysis in the first year of business raises doubts. Can a new entity benefit from this simplification?
A shareholder’s trademark used by a company raises questions about the terms of its use and remuneration from a transfer pricing perspective.
For several years, the answer to this question has been subject to debate, as evidenced by the numerous requests for individual tax rulings in Poland submitted by taxpayers. Some case law and tax ruling practice indicated that, where only the cost base changes under a cost-plus model, while the mark-up percentage remains unchanged and there…
Public CbCR is becoming mandatory for the largest corporate groups. What do the new rules mean for reporting and risk management?
Does the Coca-Cola dispute with the IRS show that years without objections from the tax authorities do not necessarily guarantee tax certainty?
Although transfer pricing deadlines are a permanent feature of the tax calendar, they still tend to surprise taxpayers each year. However, documentation obligations can be planned well in advance. For this reason, related parties should ensure timely verification of their controlled transactions, applicable documentation thresholds, and available exemptions.
How to correctly determine the income covered by IP Box, and where do transfer pricing rules come into play in this process?
The judgment of the Polish Supreme Administrative Court (NSA): a tax authority cannot automatically challenge a transaction price simply because it disagrees with the valuation method applied. When questioning the arm’s length nature of a transaction, the authority must demonstrate far more than mere reservations regarding the adopted methodology.
Can a taxpayer confirm in the TPR form that its transfer prices were arm’s length if it has previously adjusted its taxable income to an arm’s length level? A recent judgment of the Voivodeship Administrative Court in Gliwice suggests that a mere adjustment of the CIT settlement does not determine whether the conditions of a…