Magdalena Dymkowska of MDDP provides a guide to the vagaries of the Polish transfer pricing regulations and explains why the applicability of the arm’s-length rule may leave multinational companies somewhat surprised. Multinational companies that are familiar with transfer pricing...

Keep your arm’s-length distance – how to meet Polish TP obligations Multinational companies that are familiar with transfer pricing (TP) issues in their countries might raise their eyebrows over the kinds of transactions that are subject to the arm’s-length rule in Poland. Usually,...

Individuals responsible in a company for financial matters should not associate transfer pricing only with compliance obligations. Already at the stage of planning transactions with related entities, it is worth remembering about TP regulations. This will ensure the transaction is...

Starting 2021, related entities with the status of a micro or small business may prepare local files without a benchmarking analysis. Also in the TPR form, taxpayers do not fill in the boxes related to the analysis. Until now, these entities were only released from the need to file...

Property tax in the real estate business with elements of investment accounting October 27, 2022 | 10:00 a.m.: Register Issues related to property tax seem to be relatively easy at first glance. In practice, a lot of doubts arise, especially related to the scope of...

The latest interactive TP-R forms were published on 28 September (Wednesday) on the Ministry of Finance’s website. The forms are relevant for the IC-transactions carried out FY 2021. The release results from the regulations published by the Polish Ministry of Finance (for CIT and...

The CIT Act-introduced transfer pricing regulations target primarily controlled transactions made between related entities. However, not everyone is aware that they also apply to transactions with third parties having their registered office or management in the territory or in a...

Tax changes related to employment in Poland from the payer’s perspective New regulations that have significantly changed the Polish tax system for the second time in 2022 came into force on July 1. The tax amendment, the so-called Polish Deal 2.0, modifies the personal income tax...

Documentation obligation not triggered by the redemption of shares – another favorable decision by a District Administrative Court Redemption of shares in a company is an institution governed by the Code of Commercial Companies and Partnerships (KSH). It has been disputed between...

MDDP and Osborne Clarke Scholarship Program for Ukrainian children Since the beginning of the war in Ukraine, MDDP and Osborne Clarke, in addition to ongoing support for refugees in areas where they need help most, sought to create a long-term aid program for Ukraine. Having gathered...

MDDP advised Lone Star Funds on the acquisition of 3 office buildings MDDP provided tax advisory to Lone Star Funds on the acquisition of 3 office buildings from Cavatina (Carbon Tower in Wroclaw, Tischnera Office and Ocean Office Park A in Krakow). The value of the offices amounts...

Type of remuneration established within transaction should reflect the functional profile The functional analysis is a key item of the transfer pricing documentation. It determines precisely the functional profile of the parties to the controlled transaction and introduces the risks...

MDDP on Polish Taxes I Real estate companies – the reporting deadline is approaching September 8, 2022 at 11:00 a.m. The real estate companies and their shareholders are obliged to report their shareholding structures to the tax authorities in Poland.  The provisions are new and give...

Which transactions are not subject to documentation obligations? There are transactions or activities between related entities that may at first glance imply transfer pricing obligations. They are actually not controlled transactions in the context of TP regulations. Since Local File...

To document a loan, or not, that is the question! Financial transactions are among the most frequently documented transactions taxpayers make with related parties. In fact, they accounted for over 40% of the reported transactions according to the TPR-C forms filed for 2019. Due to...