Some taxpayers currently compiling Local Files and TP-R forms for 2021 will not complete their struggle with transfer pricing on 31 December 31 (if their tax year matches the calendar year). They will face additional obligations related to Master File for 2021. What is Master File? The Master File is (shortly) an integral part of…
There is less than a month left to meet the transfer pricing reporting deadlines. One of the obligations is to file to the Polish tax office a statement on transfer pricing documentation and on the arm’s length nature of the transaction. The statement shall be signed by members of the company’s management board. For most…
The deadline for filing TPR for 2021 with the Head of KAS is looming – 31 December 2022! Do not work on the TPR at the very last minute. Instead, complete it as early as possible. Failure to comply with this obligation can be costly. The prospect of penalties Completing the form hastily may result…
This is the final call to make sure you meet the obligations related to preparing transfer pricing analyses. Due to the Covid-19 pandemic, in 2021, the deadlines for meeting the documentation obligations for 2021 (including TP analysis) have been extended until the end of 2022 for most taxpayers. Update of TP analysis One of the…
Deadlines for meeting transfer pricing obligations for 2021 are looming. Less than 2 months are left until 31 December. Just like every year, there are quite a lot of formalities to be completed. Those who have not yet prepared documents for 2021: we have summarized the obligations you must meet. Every week we will remind…
From 1 January 2021, specific CIT taxpayers may choose the form of their income taxation: they may settle on general principles (already known) or opt for a new simplified form of taxation, i.e. the lump sum on the income of companies (the so-called Estonian CIT). What is the difference? In a regular CIT, the taxation…
We have some good news for taxpayers right before the end of the year and the beginning of intensive works on documenting and reporting transactions with related parties and tax haven entities. On 21 October (Friday), the third version of the TPR-C Guidebook was published on the Ministry of Finance’s website. It supplements and extends…
In the ruling no. I SA/Gl 233/22 of 31 August 2022, the District Administrative Court in Gliwice repealed the decision of the Head of the Silesian Customs and Tax Office in Katowice on the reduction of CIT in 2016. The case concerned the acquisition and lease of trademarks from a related entity where the costs…
On 13 October 2022, the amendment to the Commercial Companies Code entered into force[1]. It introduced provisions on the group of companies, including a new instrument: binding instructions. According to the new provisions of the holding law, the parent company may issue a binding instruction to a subsidiary in order to pursue the common interest…
Transfer pricing continues to attract the attention of tax authorities. Major additional income assessments and successfully completed controls (from the perspective of tax authorities) are summarized by the National Revenue Administration – it releases information on the amount of the additional assessment and the exact scope of the control. Last week saw two of such…