The amendment of Poland’s CIT act includes substantial
changes to required transfer pricing documentation for
Recent amendments to Poland’s Corporate Income Tax act
includes substantial changes to taxpayer’s required transfer
pricing documentation. The new rules are in effect from 1 January
2017 - however CBC reporting obligation starts from 2016.
The related entities threshold will rise from a shareholding of
5% to a shareholding of 25%. The transfer pricing requirements will
be determined based on the taxpayer’s business size.
If in a preceding tax year the taxpayer’s total annual
cost or revenue did not exceed €2m there will be no obligation
for transfer pricing documentation for transactions with related
Taxpayers exceeding the €2m threshold will be obliged to
prepare transfer pricing documentation and to submit a statement
confirming the completeness of the documentation within the annual
income tax return deadline.
After exceeding the €10m threshold, a Polish comparable
data analysis (benchmarking study) and reconciliation of the
financial data with the approved financial statements will be
required. Also, submission of the additional attachment to the
annual income tax return (CIT-TP form), being a summary of data
presented in the documentation.
If a taxpayer exceeds the €20m threshold, a master file
(transfer pricing documentation at group level) will be
The value threshold of transactions subject to reporting will
also, on principle, depend on the taxpayer’s business size
and will vary from €50,000 €500,000.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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In this respect, Cyprus has shown remarkable zeal and a commitment to introducing national legislation to implement these reforms.
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