The arm’s length principle applies to all entities conducting transactions with related parties and to all transactions – regardless their value. Even if a transaction does not exceed the documentation thresholds and does not trigger the obligation to prepare local transfer pricing documentation, it is not exempt from complying with the arm’s length principle. Transfer…
The issue of intra-group transactions in the context of value-added tax (VAT) is increasingly attracting the attention of the Court of Justice of the European Union (CJEU). Recent cases underscore the importance of delineating the boundaries between direct tax (CIT) and indirect tax (VAT) regulations, as well as the significant practical implications that transfer pricing…
The Organisation for Economic Co-operation and Development (OECD) plays a pivotal role in shaping the global tax landscape, particularly in the context of the digital economy. Its objective is to establish a more equitable and predictable international tax framework that addresses the challenges posed by globalization and the operations of multinational enterprises. In response to…
Modern companies operating in international markets face the challenge of aligning customs and transfer pricing policies. A lack of consistency between these areas can lead to significant tax, operational and financial risks. For this reason, close cooperation between customs and transfer pricing departments is essential – only through collaboration can risks be effectively managed, and…
Consortia are a commonly selected form of cooperation for the execution of large-scale projects, particularly in the construction, engineering, and financial sectors. The formation of a consortium typically serves the purpose of jointly executing a specific commercial undertaking which, due to its financial, logistical, technical, or organisational complexity, exceeds the capacity of a single entity.…
Znaczenie znaku towarowego w budowaniu wartości firmy Znak towarowy to chronione prawem oznaczenie, które identyfikuje produkt lub usługę jako pochodzącą z określonego źródła. Znak towarowy to jeden z kluczowych elementów budujących tożsamość przedsiębiorstwa na rynku – pozwala odróżnić towary lub usługi jednego przedsiębiorcy od innych. Może przyjmować różne formy – od nazwy, logo, przez kształt…
In recent years, transfer pricing policy has evolved from a purely tax-focused document into a key component of broader compliance strategy. Regulatory changes – both at national and EU levels – now require transfer pricing (TP) policies to address not only tax regulations but also customs matters, environmental concerns, and corporate governance (ESG) considerations. Why…
The TP-R form and transfer pricing documentation relate strictly to a specific financial (tax) year. This means that the data presented in these documents – such as transaction values or profitability indicators – should refer exclusively to that reporting period. In practice, however, businesses may, for various commercial reasons, present averaged data, e.g. from a…
In recent years, public companies have been subject to new obligations relating to transactions entered into with related parties. These obligations arise under Chapter 4b of the Act on Public Offering[1] and apply to material transactions. According to the Act on Public Offering, a material transaction is one whose value exceeds 5% of the company’s…
A well-designed and up-to-date transfer pricing model is crucial for ensuring coherent tax compliance and mitigating fiscal risks. However, the dynamic nature of market conditions and even the most carefully developed transfer pricing frameworks can require periodic updates. Why is maintaining an up-to-date transfer pricing model important? The primary purpose of transfer pricing model is…