Transfer prices – services
On 1 January 2019, another amendment to the transfer pricing legislation entered into force. The new regulations imposed an obligation on taxpayers to prepare local transfer pricing documentation for each controlled transaction of homogeneous nature whose value...
Services
- Analysis of documentation obligations
- Preparation or verification of transfer pricing documentation and Master File group documentation
- Preparation, updating or verification of comparative analyses
- Development of transfer pricing policy
- Support in restructuring processes
- Assistance in meeting the requirements of documentation and reporting obligations (including preparation of TPR-C information, preparation of a management declaration)
- Support for negotiation of price agreements (APAs) and mutual agreement procedure (MAP)
- Support during tax audits
- Ongoing tax advice on transfer pricing
News
Tax consultation – clarification of information TPR-C and TPR-P
The Ministry of Finance has launched a tax consultation on the draft document "Questions and answers on information TPR-C and TPR-P for 2019". The tax consultation will run until 22 May 2020. Proposals for opinions, requests and comments on the draft, together with a...
Publication of TPR interactive forms
Interactive forms were published on the Tax Portal: transfer pricing information for legal entities - TPR-C (2) transfer pricing information for natural persons - TPR-P (2) These forms are used to submit transfer pricing information for the tax year starting after 31...
Ministry of Finance
– Transfer prices
Questions and answers
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...
dr Jarosław F. Mika
Leader of TP’s practice; doctor of economics in finance; tax advisor, member of the Programme Council of the Transfer Pricing Institute; author of book publications on transfer pricing; trainer of training courses for entrepreneurs and tax administration bodies; member of the Competition Commission of the 3rd edition of the competition for the best thesis on tax law organized by the National Chamber of Tax Advisors; specializes in settling financial and service transactions conducted by related entities.