
Transfer pricing adjustments – a tool for restoring the arm’s length nature of controlled transactions
Transfer pricing adjustments as a tool for restoring arm’s length conditions. Legal requirements, tax risks, VAT implications and Polish practice.

Cost segregation is a detailed identification of fixed assets based on tax regulations and Polish Fixed Assets Classification as well as determining the initial value of fixed assets including indirect costs.
| Goals | Benefits |
Depreciation of fixed assets | Higher depreciation rates available. |
| Real Estate tax | Precisely defined structures to be taxed and their tax base. For an investment located in several communes, tax base is determined for each commune. |
| Preparing real estate (investment) for sale | Transparent structure of fixed assets and better results in due diligence ordered by a buyer. |
| Inventory of property | Property review and the possibility of professional marking of fixed assets. |
| Real Estate clause | In practice, it often turns out that after cost segregation the entity does not meet the definition of a real estate company and the clause does not apply. |
| Fixed Assets | Initial value | Depreciation rate | Depreciation | Minimal CIT on Real Estate | ||||
| Before | After | Before | After | Before | After | Before | After | |
| Wind farm | 1000 | 4,50% | 45 | 20 | 2 | |||
| Foundation for the turbine | 100 | 4,50% | 4,5 | 5 | ||||
| Turbine tower | 250 | 4,50% | 11,25 | 0 | ||||
| Turbine nacelle with generating set | 250 | 7% | 17,5 | 0 | ||||
| Blade and hub | 200 | 7% | 14 | 0 | ||||
| HV cables | 150 | 4,50% | 6,75 | 0 | ||||
| GPO | 50 | 10% | 5 | 0 | ||||
| Total | 1000 | 1000 | 45 | 59 | 20 | 7 | ||
Increasing monthly depreciation write-offs up to 2 times.
Up to 3-fold reduction in Real Estate tax on structures.

Partner | Tax adviser
E: rafal.kran@mddp.pl
T: +48 693 290 919

Manager
E: lukasz.szatkowski@mddp.pl
T: +48 570 898 499

Transfer pricing adjustments as a tool for restoring arm’s length conditions. Legal requirements, tax risks, VAT implications and Polish practice.

Polish tax in 2026 digital tax compliance becomes business reality

Eligible costs under the research and development (R&D) tax relief