Identifying the links between parties to a transaction is not only crucial, but also one of the first things a taxpayer should do before proceeding with transfer pricing documentation and reporting obligations.  Given the high volatility and uncertainty of the tax laws, it is worthwhile...

Or rather, on the premise of beneficial ownership, since, despite the name of the project (‘clarifications on withholding tax collection’), their scope is limited to the aforementioned aspect. The deadline for comments is 10 October. The draft clarifications raise even...

Safe harbour is a mechanism to reduce documentation and transfer pricing reporting obligations provided that the taxpayer meets several statutory requirements. Once such conditions are met, the taxpayer is supposed to gain certainty as to the arm’s length nature of the price...

Group documentation is treated a bit lightly by taxpayers. After the hassle of preparing Local File with transfer pricing analyses and properly completing and submitting the TP-R form, many taxpayers would like to take a breather from transfer pricing obligations. However, we would...

In today’s dynamic business environment, organizations face constant challenges to remain efficient and competitive. In this context, one of the key aspects that often consumes a lot of time and resources is the preparation of various documents, such as financial records, reports,...

Changes in cross-border and domestic reorganizations On September 15th, 2023 an amendment to the Polish Commercial Companies Code came into force, introducing new types of domestic and cross-border reorganizations. Following the amendment, changes to income tax acts and Tax Ordinance...

Higher amount of exemption for financing meals for employees On September 1, 2023 the Regulation of the Minister of Family and Social Policy came into force, amending the Regulation on detailed rules for determining the basis for pension and disability contributions. According to...

The methods used to verify the transfer price are indicated in Article 11d of the CIT Act, i.e.: the comparable uncontrolled price method, resale prices, cost-plus, net transaction margin, profit sharing. However, taxpayers are not obliged to use only the above-mentioned methods...

On 17th August, the European Commission published rules governing the implementation of the CBAM mechanism during its transitional phase. The transitional phase starts already on October 1, 2023 and will last until the end of 2025. During this period, importers will be required to...

The primary purpose of a benchmarking analysis is to establish and verify that the terms and conditions in transactions between related parties correspond to the arm’s length principle. Although only one of the integral elements of transfer pricing documentation, these analyses are...

Marketing contracts are an area where, in addition to the legal risks, particular attention should be drawn to the correct wording of tax provisions and tax consequences of the activities described therein. For instance, the supply of products to an influencer in exchange for promotional...

MDDP experts in ITR World Tax Leaders 2024 As many as 12 MDDP experts have been listed in the ITR World Tax Leader ranking. This means that again MDDP has the LARGEST number of distinguished experts among all companies in Poland! MDDP experts are distinguished in 5 key categories: General...

MDDP advised Griffin Capital Partners and Redefine Properties on the acquisition of Stokado MDDP has advised Griffin Capital Partners, a Polish investor and a private equity and real estate asset management firm, and Redefine Properties, a South African investor, on the acquisition...

Identifying the links between the parties to a transaction is one of the first and at the same time the most important steps in the process of identifying transfer pricing obligations. Correct determination of linkages is particularly important if the parties to the transaction wish...

Deposit Refund System – a revolution for now The introduction of a deposit refund system in Poland is a huge financial and logistical challenge that awaits entrepreneurs in the coming years. What will change? The deposit refund system is a way to collect used beverage packaging...