We cordially invite you to the business breakfast “About transfer pricing over a morning coffee”,
on 27th of September from 10:00 to 12:30 at the Deloitte office in Warsaw (Q22 building, Al. Jana Pawła II 22).
Many multinational companies struggle with transfer pricing requirements in Poland. It is very important for the activities of many companies to be able to take advantage of the public funds available to finance investments and of tax exemptions and reliefs.
So, if you are a manager who dealing with tax issues (transfer pricing) or issues related to obtaining subsidies, exemptions and reliefs for investment financing, we would like to invite you to a free tax breakfast meeting, during which we will discuss:
- transfer pricing documentation and reporting obligations in Poland (what is coming up for us in the next months of 2024),
- transfer pricing controls (which is on the agenda of the tax and duty authorities),
- transfer pricing penalties in Poland (including personal responsibility) – a practical guide,
- tax reliefs, subsidies and support for financing investments in Poland.
The event will be held in Polish.
Due to the requirements of the Data Protection Act, please confirm your participation in the event via register form. Registration is available until 26.09.2024 till 12:00. The organizers reserve the right to reject applications from companies competing with Deloitte Polska.
Contact person:
Izabela Brzozowska
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Transfer pricing regulations in Poland have been changed several times over the last years. Poland became a country with various country-specific transfer pricing compliance requirements, different from those of other OECD countries.
For example:
- TPR form must be submitted by taxpayers and include specific data about transfer prices in material transactions with related parties,
- TPR form must be signed by management board member with Polish PESEL number,
- transactions exceeding specific thresholds should be covered by the transfer pricing documentation, and even small transactions need to be concluded at arm’s length and are usually verified at tax audits,
- transactions with unrelated parties which conditions were agreed centrally are subject to transfer pricing documentation and should be at arm’s length,
- transactions with directors and board members fall under the transfer pricing requirements which means that they should be at arm’s length and covered by the transfer pricing documentation,
- Polish transfer pricing documentation template is not fully compliant with OECD reports and some specific elements should be added.
Statistics show that no. of tax audits focused on transfer pricing in Poland increased by almost 25% over the last 3 years and that almost 50% of such audits end with questioning the arm’s length nature of transfer pricing (and the CIT tax liability).
At the same time, in accordance with Polish corporate income tax and fiscal penal regulations:
- Persons responsible for tax settlements (e.g. the management board, the finance director, the tax manager, the chief accountant, etc.) are liable to tax penalties for not at arm’s length terms of related party transactions (even where the dispute relates to the assumptions used in estimating the market value). Individual penalties may be imposed for non-compliance with the tax regulations, e.g. if the transfer pricing documentation does not cover all material transactions or if the TPR form was not submitted on time.
- Such responsibility is personal and separate from fines imposed on an entity. Each person considered responsible by the tax authorities can be personally fined with a penalty of up to EUR 7.8m (current approx. amount).
Please find out more about transfer pricing controls from the Deloitte report:
Report: Transfer pricing audits in Poland in 2023
You are cordially invited!
