Beginning of a year brings (even more) obligations – ‘to do’ list for transfer pricing in Q1 2022

After a demanding December, some taxpayers will not rest at the beginning of the year. Taxpayers will face these obligations in Q1 2022: CBC-P notification Who? This obligation applies to entities belonging to capital groups that must submit CBC-R report in a country other than Poland. The obligation is imposed when consolidated revenues of a…

Changes in transfer pricing as of 1 January 2022

Among the numerous legislative changes, starting from 1 January 2022 transfer pricing regulations have also been amended and change formal and documentation obligations. The major changes include: Changes to formal obligations: TP-R Form – the taxpayer will be required to submit the TP-R form to the Head of the Tax Office competent for the taxpayer…

New rules for documenting transactions with tax havens – are you prepared?

A favourable change for the taxpayers is the proposed simplification under the so-called “Polski Ład” to apply retroactively, i.e. from 1st of January 2021. These changes will include removed obligation to prepare transfer pricing analyzes (analyzes justifying arm’s length character of transaction) in the case of tax haven transactions made with unrelated entities. At the…

Year end is the time to fulfill transfer pricing obligations for FY 2020

The deadline for meeting FY 2020 transfer pricing obligations has been extended by 3 months and falls on December 31, 2021. Taxpayers should prepare and report to meet the legal requirements. Failure to file a statement or transfer pricing information form (TP-R) or filing them late or with information inconsistent with the facts, may trigger…

2017 and 2018 Benchmark Analyses becoming no longer valid

Since 1 January 2019, all taxpayers obliged to prepare transfer pricing documentation have also been required to prepare dedicated transfer pricing analyses. In principle, benchmark analyses are valid for 3 years from their preparation. Therefore, a vast majority of benchmark analyses that were prepared by taxpayers for the first time for 2017 or 2018 are…

Transfer Pricing Guide

The process of sealing the tax system continues. Subsequent changes in tax regulations resulting from decisions of international institutions and national authorities are being introduced to the legal orders in individual jurisdictions.The high scrutiny of the tax authorities is still focused on transfer prices, and the number of tax audits of intragroup transactions continues to…

Upcoming deadlines for fulfilling the transfer pricing obligations for 2019 and 2020

In case of taxpayers meeting certain criteria (details below), the first quarter of 2021 may require fulfilling transfer pricing obligations for the tax years 2019 and 2020. The obligations for 2019 for which the deadlines have been extended in accordance with the fourth version of the Anti-Crisis Shield are presented below. Preparation of group transfer…