New businesses and the exemption from transfer pricing analysis
The exemption from transfer pricing analysis in the first year of business raises doubts. Can a new entity benefit from this simplification?
Trademark in Transfer Pricing – how to determine an arm’s length royalty rate?
A shareholder’s trademark used by a company raises questions about the terms of its use and remuneration from a transfer pricing perspective.
Does aligning cost base always constitute a transfer pricing adjustment under Article 11e?
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 CbC-R – a report that requires decisions, not just data
Public CbCR is becoming mandatory for the largest corporate groups. What do the new rules mean for reporting and risk management?
Coca-Cola vs IRS – does a long-standing transfer pricing model really provide protection?
Does the Coca-Cola dispute with the IRS show that years without objections from the tax authorities do not necessarily guarantee tax certainty?
Transfer pricing in 2026 – Local File, TPR and Master File deadlines for FY 2025
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.
IP Box and transfer pricing – where do these two worlds meet?
How to correctly determine the income covered by IP Box, and where do transfer pricing rules come into play in this process?
NSA on share valuation: criticizing the method alone is not enough
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.
TP Statement and non-arm’s length transfer prices – does a CIT adjustment eliminate the risk?
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…
Free-of-charge share redemption and transfer pricing consequences – recent Polish Supreme Administrative Court rulings
The Supreme Administrative Court (SAC) is increasingly indicating that certain capital transfers may also constitute a controlled transaction within the meaning of transfer pricing regulations. Such an approach also applies to arrangements that were previously often regarded as tax-neutral, including the free-of-charge share redemption. In practice, this may entail an obligation to conduct a thorough…