Tax adjustments in VAT, CIT, TP and customs | Everything you need to know before closing the year

Duration: 4h | Access fee: PLN 890 net

The end of the year is getting closer and closer. Not only for companies with a calendar-based fiscal year is this the time for doing the final settlement for the entire year 2022. It is still worth checking the settlements carefully, with a view to whether any adjustments to the settlements or prices/conditions may be necessary.

Adjustments raise numerous questions, among others the following ones:

  • Should the settlement be included in the tax result retroactively or on an ongoing basis?
  • What conditions need to be met for the adjustment to be recognised in the tax result at all?
  • Will it be necessary to issue an invoice?
  • Should VAT on the adjustment be recognised on an ongoing basis or in the period subject to adjustment?
  • Will the customs value of the imported goods change?
  • Does the adjustment constitute a so-called transfer pricing adjustment requiring reporting?

The issue of adjustments still raises many questions of interpretation, both in terms of definitions, their accounting and the individual conditions for a secure tax settlement. Accounting for adjustments in VAT and customs settlements is yet another challenge.  In the event of a change in the originally invoiced prices between related parties, such an adjustment may have to be reported and included in the transfer pricing documentation.

Therefore, it is worth addressing this topic now in order to close the tax year with a clear head and to be prepared for the possible consequences of making adjustments after the end of the year.

 

Part 1 – introduction to the issue of adjustments

Procedural law

  • Right to adjust tax returns
  • Suspension of the right to adjust tax returns
  • Adjustment of tax returns and the statute of limitations
  • Fiscal penal consequences of submitting a tax return adjustment
  • Adjustment of tax returns by a tax authority
  • Adjustment of declarations included in tax returns

CIT

  • Principles of accounting for adjustments other than transfer pricing adjustments (on a current or retrospective basis).
  • How do you deal with the case where the revenues received, or costs incurred in a given period are lower than the value of the adjustment.
  • Cost adjustments resulting from inadequate payment methods (Article 15d of the CIT Act).
  • Bad debt tax credit and transactions between related parties,

Price adjustments in related-party transactions 

  • The essence and purpose of transfer pricing adjustments.
  • Differences between transfer pricing adjustments and other settlements which, based on tax ruling and judgments issued to date, do not meet the definition of transfer pricing adjustments under Article 11e of the CIT Act.
  • Conditions to be met by taxpayers when making transfer pricing adjustments within the meaning of Article 11e of the CIT Act.

VAT

  • Situations where adjustments affect VAT settlements.
  • Possibility of documenting an adjustment with an accounting note.
  • Necessity to issue a correcting invoice.
  • Collective correcting invoice as a practical solution.

Customs:

  • Situations where adjustments affect customs duties.
  • Customs consequences of an adjustment depending on how it is documented (invoice/note).
  • Impact of the adjustment on customs obligations and authorisations.
  • Solutions intended to minimise the customs burden (including administrative burden) resulting from adjustments.

Part 2 – Fiscal evaluation of specific cases

  • Analysis of practical problems – several case studies with analysis of practical implications
  • Q&A: Additional questions and answers.

 

 

Tax and finance department staff, finance directors, tax managers, financial controllers, chief accountants, procurement and sales department staff. Representatives of Polish and foreign companies, including corporate groups, in which price changes in commercial settlements are an important element of the business process.

 

  1. Knowledge of all tax consequences of price adjustments
  2. Practical examples of the application of regulations.
  3. Training presentation
  4. Recording of the training available for 14 days after receiving the link.
  5. Certificate of participation.
  • The cost of access to the workshop is PLN 890 net per person.
  • The second and subsequent participants from the same company are entitled to a 10% discount.
  • Once you have your order acceptance confirmed by email, you will be subsequent emailed an individual link a web page where you can replay the training course. Access to the training is active for 14 days.
  • The MDDP training is a paid online workshop for MDDP clients and business partners. We reserve the right to select registrations and to refuse to accept orders, especially in the case of registrations of persons representing competing entities.
Agnieszka Kisielewska

Partner | Tax advisor
Email:agnieszka.kisielewska@mddp.pll
Tel.: +48 600 097 363

Katarzyna Kozakowska

Senior Manager | Tax Advisor
Email: katarzyna.kozakowska@mddp.pl
Tel.: +48 608 581 583

Jakub Warnieło

Manager | Tax Adviser
Email:jakub.warnielo@mddp.pl
Tel.: +48 504 399 973

Marta Klepacz

Senior Manager
Email: marta.klepacz@mddp.pl
Tel.: +48 533 889 036

Marek Przybylski

Manager | Tax advisor | Legal Counsel
Email: marek.przybylski@mddp.pl
Tel.: +48 509 567 231