Questions and answers – TP
Who is required to prepare the Master File?
According to the applicable regulations, entities are obliged to attach the Master File to the local documentation: those belonging to the group of related entities, whose consolidated revenue in the group of related entities exceeded PLN 200,000,000 or its equivalent...
What are the criteria for considering the activity as a restructuring of the activity?
The new definition of restructuring, introduced by an amendment to the Act, indicates two key criteria: significant change in commercial or financial relations, including termination of existing contracts or change of existing conditions, a transfer between related...
When is it possible to apply transaction netting?
If related parties achieve a result on a transaction that differs from market conditions, but at the same time another transaction between the same parties achieves a market result that makes it possible to cover deficiencies in relation to market conditions or...
How to assess that a controlled transaction is homogeneous?
In assessing whether a controlled transaction is homogeneous, account is taken: the homogeneity of the transaction in economic terms, and the comparability criteria set out in the implementing rules and transfer pricing verification methods and other relevant...
What research methods are used to make a comparative analysis?
Comparative analysis is usually carried out using the deductive and/or additive method. Deductive approach is characterized by the use of specialized databases, in order to determine a set of transactions or entities potentially comparable. The addition (addition)...
In what form should a declaration by the board of directors on the preparation of local transfer pricing documentation and on the market level of transfer pricing be submitted?
A declaration that local transfer pricing and market level transfer pricing documentation has been prepared is to be submitted by electronic means of communication in accordance with the provisions of the Tax Ordinance. The declaration of the management board should...