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The amendment to the regulation on transfer pricing

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On 18 July, 2013, entered into force amendments to the Regulation of the Minister of Finance on transfer pricing, introducing important changes that affect the manner of conducting tax audits on transfer pricing. The amendment included with the 2010 OECD Guidelines on transfer pricing for multinational enterprises and tax administrations.

Below are the most important changes:

  • Abolition of priority comparable uncontrolled price method, when determining the transaction price – a decision on the choice of method will take into account the so-called ‘arm’s length’ principle;
  • Introduction of the obligation to carry out the inspection authority comparable transaction analysis prior to estimation;
  • Clarify the method of profit distribution;
  • Adding a chapter governing the conduct and consequences of restructuring activities;
  • Introduction of directory services with a low added value and simplified control of transfer pricing for such services;
  • Change in the method of determining the market value of the R & D services.

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