Why TP obligations for 2024 matter for businesses The upcoming autumn marks the need to fulfil transfer pricing obligations for 2024. Businesses are required to prepare the Local Transfer Pricing Documentation (Local File) for 2024 and keep in mind the upcoming deadlines relating to the TPR form and the Group Transfer Pricing Documentation (Master File).…
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…
“Debt analysis,” “debt capacity,” “analysis of debt servicing ability” – many terms exist in the world of transfer pricing, but they all refer to the same issue. It is no longer a secret that tax authorities, when examining financial transactions, check not only the level of applied interest rates but also other conditions, including the…
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…
Transfer pricing analysis forms the backbone of the Local File and the TPR (Transfer Pricing Report) form. Find out how to avoid income reassessments and prepare an analysis robust enough to pass a customs and tax audit. Introduction At first glance, everything appears to be in order. The company’s results fall within the range. Documentation…
Deadlines for transfer pricing obligations in Poland – TPR form and the Local File for 2024 – are approaching fast. Find out how much time is really left, which mistakes to avoid, and why acting now – before the end of summer – is your best option. Only 60 days after the summer break That’s…
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 –…
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 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. …
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…