Today, we present the fourth and final entry in our series on transfer pricing. From previous posts, you already know what transfer pricing is (and certainly what it isn’t), who related parties are, and how to assess whether the prices applied in an intragroup transaction are at arm’s length. You’ve also become familiar with the…
Price adjustments are still not a clear-cut issue and raise questions for taxpayers. In 2023, administrative courts issued rulings on adjustments in three main areas described below. Definition of transfer pricing adjustments It is worth recalling that TP adjustments refer to transactions between related parties and are an important part of business practice. However, their…
The fundamental rule in transfer pricing is the arm’s length principle. When applied correctly, it ensures that related parties conduct transactions under terms that are consistent with those which would be agreed between independent parties. But how do we know that the conditions established in a given transaction are market-based? How can this be verified?…
Intra-group loan Intra-group loans, like other related party transactions, should be made on an arm’s length basis. In order to verify loan transactions to comply with the arm’s length principle, the comparable uncontrolled price method is most often used in the external variant. Data for this analysis is obtained from external specialized databases. Tax authorities…
Have you heard of the “six degrees of separation” theory? It’s a concept that assumes that, as a resident of Earth, you can meet any other person in the world with just six or fewer mutual connections between you and that person, whether through acquaintances, friends, or their family members. What does this theory have…
In the dynamic business world, planning of settlement between related parties is becoming an essential part of groups’ business strategy. Changes in the market affect the development of new technologies, products and services. They determine the activities of companies in achieving economic benefits and competitive advantages. Well planned settlements are the basis for business success,…
An APA (advance pricing arrangement) is an agreement on the transfer price applied in transactions between related parties, concluded between a taxpayer and the Head of the National Revenue Administration. The APA takes the form of an administrative decision and constitutes a confirmation by the tax authority of the arm’s length principle of settlements between…
When we talk about transfer pricing, we’re definitely thinking about transferring funds. And probably abroad. Most likely to a tax haven. If this was your first association upon seeing the title, make sure to read this article to the end. We’ll demystify transfer pricing, show you what it really is, and explain why it’s worth…
Recently, there has been a noticeable increase in interest in ESG topics. This is due to two reasons: the increase in stakeholder interest in off-balance sheet activities and the extension of the ESG reporting obligation (so far, the ESG issue in Poland concerned about 150 entities, but due to the change in the rules, from…
The deadline for submitting the CBC notification (CBC-P) for 2023 to the Head of KAS is coming soon – 31 March 2024 (for all entities whose financial year matches the calendar year). This obligation covers entities belonging to capital groups that are subject to the CBC-R. Who? The obligation applies to entities (which are not…