New transfer pricing regulations in Poland in force since January 1st, 2017
Channel: MyTPAGlobal
Date: 2017-11-15

New transfer pricing regulations in Poland were introduced into the tax system to implement the instruments developed by OECD within BEPS framework. However, there are some different items and obligations included in Polish regulations that are not part of the OECD Guidelines.

Lawmaking activity in the field of transfer pricing is followed by an increasing number of transfer pricing audits launched by Polish tax authorities.

The Ministry of Finance initiates various activities to ensure effective tax audits:
- Establishing units specialized in transfer pricing issues,
- Engaging highly experienced specialists, and
- Providing tax authorities with an access to commercial databases.

Significantly expanded obligations in the field of transfer pricing comprising:
- Preparing transfer pricing documentation (Local file and Master file),
- Preparing benchmark analysis,
- Filing additional documents, e.g. simplified statement on transactions and other occurrences between related entities (CIT-TP), Country-by-Country Report, Country-by-Country notification,

Obligation to prepare transfer pricing documentation depends on these factors: (i) the level of revenues or costs generated by the taxpayer and (ii) the value of transactions made with related entities.

The minimum obligation to prepare transfer pricing documentation at the local level applies if revenues or costs generated by taxpayers exceed a threshold of EUR 2,000,000.

One of the challenges some taxpayers are facing is the obligation to prepare Country-by-Country notification - deadline for filing the first Country-by-Country notification is October 31st, 2017.

The scope of the transfer pricing obligations since January 1st, 2017 is more extensive than that of previous years, so meeting the new obligations may be a complicated and time-consuming process. Therefore, it is recommended to verify potential obligations in the field of transfer pricing for your company and launch appropriate works as soon as possible.

The webinar will address:

- Summary of Polish transfer pricing legislation in force since January 1st, 2017.
- Obligation to prepare benchmark analysis in Poland.
- Simplified statement on transactions and other occurrences between related entities (the so-called CIT-TP).
- Country-by-Country reporting according to Polish regulations.

Speakers

Agnieszka Krzyżaniak, Transfer Pricing Manager at MDDP, Poland
Marta Klepacz, Senior Consultant at MDDP, Poland