This is a page for the tag Transfer Pricing
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 →
Transfer pricing in Poland in 2025 – thresholds, limits and documentation
Transfer pricing in Poland in 2025 remains a focus for both tax authorities and businesses engaging in transactions with related entities. The regulations in this area are crucial for maintaining financial transparency, avoiding disputes with the tax office and minimizing the risk of penalties. In 2025, the rules continue to... Read More →
Catering costs for employees – a new approach by Polish tax authorities
Major changes in the position of Polish tax authorities on the financing of catering costs. The National Revenue Administration (Krajowa Administracja Skarbowa, or KAS) in Poland has recently liberalized its approach and changed the interpretation of regulations in favour of taxpayers. According to the new interpretation, an employer may now... Read More →
The FASTER Directive is approaching: Major changes to the Settlement of Withholding Tax (WHT)
The FASTER Directive on Withholding Tax (WHT) The European Union aims to simplify and speed up the procedures related to withholding tax relief in order to increase the efficiency of EU capital markets. The new initiative provides for the introduction of two mechanisms: withholding tax relief and a quick refund... Read More →
Increased controls in the area of transfer pricing
The Ministry of Finance has announced that tax authorities are going to increase controls in the area of transfer pricing. Data shows that in the first nine months of 2023, tax authorities conducted over 12,800 tax and over 7,000 combined customs and tax audits. In the face of globalization and... Read More →
Extension of deadlines for the filing of TPRs and transfer pricing documentation
The deadlines for the filing of the TPR and the statement on the preparation of local transfer pricing documentation for 2021 have been extended – thus, for companies whose financial year 2021 coincided with the calendar year, the deadline is, in principle, 30 December 2022. For entities whose financial year... Read More →
The obligation to prepare the Transfer Pricing documentation
We would like to inform you, that as of January 1, 2021, pursuant to Art. 11o Sec. 1a and 1b of the Corporate Income Tax Act, the obligation to prepare the Transfer Pricing documentation also applies to a controlled transaction or a transaction other than a controlled transaction, if the... Read More →
Documentation thresholds in transfer pricing in 2022
Among the many legislative changes, from 1 January 2022, also those concerning transfer pricing came into force. In particular, they point to formal and documentation issues, including those informing about the thresholds at which homogeneous controlled transactions must be documented. The transfer pricing documentation is prepared for transactions whose value... Read More →
