Tax alert


The new draft of the CIT-TP report

The Ministry of Finance has changed on November 2nd 2016 the detailed design reports CIT-TP and the regulation on elements constituting tax documentation.
A new report by CIT-TP will include 231 items (the first version consisted of 470 items), including additional information regarding the performance / receive services without remuneration.
The regulation specifies the elements while basic documentation master file documents and comparative analysis.

The deductibility of permanent establishment’s losses – the invalid judgment of Voivodeship Administrative Court in Cracow

We would like to kindly inform that on Wednesday 03.11.2015. The Voivodeship Administrative Court in Cracow issued the judgment in the case conducted by Taxonity in terms of the deductibility of losses regarding liquidation of permanent establishment. This judgment confirms possibility to offset the permanent establishment losses against domestic profits.

Business restructurings

Restructuring activities in the group according to §23a of the Minister of Finance of June 17, 2013 in terms of  transfer pricing and Chapter IX of the OECD Guidelines is understood as cross-border redeployment by a multinational enterpise of:

  • assets,
  • risks,
  • function.

In a situation where related entities move between them assets or change functions (eg. from a distributor to a contract/tool manufacturer) to the appropriateness of such transaction in the context of market prices should be made:

-       valuation of assets,

-       fix of exit payment.

Valuation of assets should be based on the valuation of the property expert, while the amount of the exit payment, should be refer to the value of royalties in the industry recognizing the value of the market being the product of royalties (ie. between the lower and upper quartiles) and a period of 3-5 years.

If you have any inquires please do not hesitate and contact us.

Amendments to the CIT - Tax Breakfast, 25th 25th October

Taxonity is pleased to inform that 'Amendments to the CIT' training will be held on

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Where: Gda?sk

Taxonity classified in World Transfer Pricing 2014 International Tax Review report

We would like to kindly inform, that Taxonity have been classified in World Transfer Pricing 2014 International Tax Review report

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which was prepared by TP Week.

Ministry of Finance has prepared a draft amendment in the scope of transfer pricing regulation.

The project is currently in consultations from February 5th 2013.

The main changes will affect:

  • Elimination of hierarchies in terms of selection of the transfer pricing method
  • Simplification of tax audits in scope of law value intangible services
  • Harmonization of procedures regarding benchmark study
  • Introduction of new definition of shareholders costs
  • Introduction of regulation regarding transfer pricing aspects of business restructurings
  •  Amendment prescription in the scope of elimination of
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