TPR Profitability – analysis, challenges and finalisation of data for transfer pricing purposes

TPR Profitability – analysis, challenges and finalisation of data for transfer pricing purposes

Transfer pricing

TPR (Transfer Pricing Report) is a key obligation for taxpayers carrying out transactions with related entities. Its purpose is to provide the tax authorities with essential information about transactions, including the reported profitability. TPR reporting is not merely a formality – it is a tool that enables quick insight into transactions and facilitates the selection…

A new perspective from the CJEU on transfer pricing adjustments and VAT – the Arcomet Case (C-726/23)

A new perspective from the CJEU on transfer pricing adjustments and VAT – the Arcomet Case (C-726/23)

Transfer pricing, Trochę o VAT

Continuing the TP and VAT series, in which we discuss the most important cases regarding intra-group settlements (see: Intra-group settlements under the scrutiny of the CJEU – key issues in transfer pricing and VAT), this time we are looking at the Arcomet case (C-726/23), which introduces a new perspective on a well-known topic. The issue…

Master File (group transfer pricing documentation) – what is it and who is required to prepare it?

Master File (group transfer pricing documentation) – what is it and who is required to prepare it?

Transfer pricing

For many taxpayers, transfer pricing (TP) compliance forms a crucial part of their annual tax closing procedures. The period from October to December is typically intensive –preparing the Local File and submitting the TPR-C form requires precision and coordination across multiple departments. Alongside local documentation, the Master File – the group-level transfer pricing documentation –…

Intra-group settlements under scrutiny by the CJEU - what does the Weatherford ruling mean for intra-group service acquisitions?

Intra-group settlements under scrutiny by the CJEU – what does the Weatherford ruling mean for intra-group service acquisitions?

Transfer pricing, Trochę o VAT

In the first article of our TP & VAT series (link: https://www.mddp.pl/intra-group-settlements-under-the-scrutiny-of-the-cjeu/ ), we outlined the general background to recent rulings by the Court of Justice of the European Union (CJEU) in this area. Today, we delve deeper into the topic by analysing the Weatherford judgment (Case C-527/23), which carries significant implications for the interpretation…

Does a gratuitous guarantee under Estonian CIT mean no transfer pricing obligations?

Corporate tax, INSIGHT, Transfer pricing, Trochę o CIT

Does a gratuitous guarantee granted to a taxpayer subject to Estonian CIT by a related entity give rise to a transfer pricing documentation obligation? According to DKIS [1] – yes – if the value of the guarantee exceeds the threshold of PLN 10 million, the taxpayer will be required to prepare transfer pricing documentation.  …