We have been running out of adjectives to describe the amendments to transfer pricing regulations. For many years, we have discussed something new almost every year. Many a time have we communicated that the new regulations are “significant” or “revolutionary” and that the amendments are “fundamental” or “thorough”. It just shows how dynamic the development of the regulations concerning that issue is. At the same time, it is important that the future “revolutionary and significant” amendments will not become a challenge beyond our limits. At present, such a challenge is the reporting of transactions with related entities, which has been submitted in an electronic form (TPR) for the first time this year.
This edition of our publication discusses changes in transfer pricing regulations.
In this issue:
- Introduction – Jacek Bajger, Monika Palmowska
- Statement on transfer pricing documentation since 2019 – is this only a formality? – Hanna Rawska, Ewa Major
- What's new in the Local File and Master File? – Tomasz Szczepanek, Robert Żaczek
- Troublesome identification of controlled transactions – Piotr Wodecki, Joanna Brodziak
- Transfer pricing reporting – a new phase – Jakub Roszkiewicz, Marta Krawcow
- Sources of information about intra-group transactions and amendments to the CCP&C – Paulina Szemiel, Monika Bonikowska
- Restructuring – definition and methods of its documentation – Barbara Popowska, Aleksandra Butowska
- Intangible, yet substantial – what’s good to know about intangibles? – Tomasz Klusek, Karolina Łukawska
- How to apply Article 15e of the CIT Act in business activities based in Special Economic Zones? – Katarzyna Darska, Natalia Księżarek
- Do you conclude transactions with related entities? Expect inspections – Piotr Wierzejski, Weronika Michalak
- Methods of eliminating double taxation under the DRM Act – Paweł Kapłan
