This is a page for the tag Transfer Pricing
MDR changes in Poland 2026: what companies must do before 1 October
From 1 October 2026, Poland’s Mandatory Disclosure Rules (MDR) will generally apply only to reportable cross-border arrangements. VAT and excise arrangements will fall outside the MDR framework, while the separate supporting-party role and the statutory requirement to maintain an internal MDR procedure will be removed. Companies should nevertheless reassess participant... Read More →
Transfer pricing and withholding tax in Poland: when do they affect each other?
Under Polish tax law, transfer pricing can directly affect withholding tax in Poland when a Polish company pays interest or royalties to a foreign related party. A WHT exemption or reduced rate may apply only to the arm’s length portion of the payment. Any excess may trigger both a transfer... Read More →
Transfer pricing documentation and Estonian CIT in Poland – what the Supreme Administrative Court of Poland (NSA) ruling means for companies
Companies that have chosen the lump-sum taxation on corporate income in Poland, commonly referred to as Estonian CIT, still need to analyse their transfer pricing obligations. The issue of transfer pricing documentation and Estonian CIT is particularly important for companies operating within capital groups, companies with foreign shareholders and businesses... Read More →
Transfer pricing adjustments in Poland under CIT rules – key principles for companies
Transfer pricing adjustments in Poland are particularly important for companies operating within capital groups, especially where settlements between related parties are calculated during the year on the basis of planned, budgeted or historical data. After the end of the tax year, it often turns out that actual costs, revenues or... Read More →
Withholding tax in Poland in numbers: what 2025 WHT statistics show
Withholding tax in Poland in numbers shows that WHT is no longer merely a technical obligation connected with cross-border payments. The 2025 statistics confirm that withholding tax remains one of the most sensitive areas of tax settlements in Poland — both in terms of the number of documents filed and... Read More →
Transfer pricing in Poland in 2026: schemas, forms and reporting changes
In 2026, transfer pricing remains one of the most demanding areas of Polish tax compliance. What matters more than ever is the quality and consistency of financial data reported in the Transfer Pricing Information form (TPR), Country-by-Country Reporting (CbC) and public CbC reporting (PCbCR) — and how well those figures... Read More →
Exit tax in Poland: when does tax on unrealised gains arise?
Exit tax in Poland, formally referred to as the tax on unrealised gains, is an issue that most often arises in connection with a change of tax residence, the transfer of assets abroad, a corporate group restructuring, or the liquidation of business activity carried out in Poland through a foreign... Read More →
Country-by-Country reporting in 2026 – filing requirements for CbC-P notification and CbC-R report
According to OECD regulations on tax information exchange, multinational corporate groups are required to report their organizational structures and financial results. The purpose of this obligation is to ensure greater tax transparency and to limit aggressive tax optimization practices. What is CbC Reporting? The primary goal of Country-by-Country (CbC) reporting... Read More →
Transfer pricing in the spotlight of the tax authorities – a growing risk for companies in Poland
The tax authorities are gradually moving from spot checks to systematic supervision of taxpayers’ settlements, focusing on areas that may lead to understatement of income or transfer of profits outside Poland. The increase in the value of income reassessments and the development of analytical tools such as JPK_CIT and KSeF... Read More →
Transfer pricing adjustments may be subject to VAT – CJEU judgment in Arcomet (C-726/23)
In its judgment of 4 September 2025 in Arcomet Towercranes (C-726/23), the Court of Justice of the European Union took a position on intra-group settlements between related companies. The CJEU ruled that the equalisation of operating margins between entities within the same group may constitute a supply of services for... Read More →
