MDDP Insight

MDDP Insight

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Corporate tax
Transfer pricing
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Recharacterization of transactions – a real threat? Yes, but only since 1 January 2019?
In the ruling no. I SA/Gl 233/22 of 31 August 2022, the District Administrative Court in Gliwice repealed...
Binding instructions to subsidiaries
On 13 October 2022, the amendment to the Commercial Companies Code entered into force[1]. It introduced...
NRA strikes back
Transfer pricing continues to attract the attention of tax authorities. Major additional income assessments...
WIRD to replace WIBOR
On 13 July 2022, the National Working Group (NGR) for reform of reference index was established. It was...
Keep your arm’s-length distance – how to meet Polish TP obligations
Magdalena Dymkowska of MDDP provides a guide to the vagaries of the Polish transfer pricing regulations...
Plan transactions with related entities smart and consider the transfer pricing perspective
Individuals responsible in a company for financial matters should not associate transfer pricing only...
Micro and small businesses out of TP obligations?
Starting 2021, related entities with the status of a micro or small business may prepare local files...
New interactive TP-R forms published by the Polish Ministry of Finance
The latest interactive TP-R forms were published on 28 September (Wednesday) on the Ministry of Finance’s...
Direct tax haven transactions – obligations involved in transacting with third parties
The CIT Act-introduced transfer pricing regulations target primarily controlled transactions made between...
Documentation obligation not triggered by the redemption of shares – another favorable decision by a District Administrative Court
Documentation obligation not triggered by the redemption of shares – another favorable decision by a...
Type of remuneration established within transaction should reflect the functional profile
Type of remuneration established within transaction should reflect the functional profile The functional...
Which transactions are not subject to documentation obligations?
Which transactions are not subject to documentation obligations? There are transactions or activities...
To document a loan, or not, that is the question!
To document a loan, or not, that is the question! Financial transactions are among the most frequently...
Another exemption unavailable for tax haven transactions
Another exemption unavailable for tax haven transactions Taxpayers for the first time need to identify...
Authorities must also exercise diligence while preparing benchmarking analyses
Authorities must also exercise diligence while preparing benchmarking analyses When preparing benchmarking...
Benchmarking analyses – authorities may err
A benchmarking analyses is a key part of the transfer pricing documentation – it confirms the arm’s length...
APA statistics for Q1 2022
The National Revenue Administration (KAS) has released the latest statistical data on APAs. Briefly:...
TP documentation obligations: more than Local File and TPR or the Master File explained
TP documentation obligations: more than Local File and TPR or the Master File explained. For many taxpayers...
TP functional profile – what you need to know
Yesterday, a draft amendment to the CIT Act was published on the website of the Government Legislation...
Not every adjustment to transaction prices is a transfer pricing adjustment
Not every adjustment to transaction prices is a transfer pricing adjustment Related parties often apply...
Ministry of Finance announces simplified rules for documenting tax haven transactions
In recent days, Artur Soboń – Deputy Minister of Finance – announced changes in CIT aimed at simplifications...
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