Poland: Transfer pricing documentation and financial transactions involving loans
Regarding an obligation of establishing transfer pricing documentation for financial transactions involving loans
Transfer pricing documentation and financial transactions involving loans
The Minister of Finance on 16 February 2022 replied to a parliamentary inquiry regarding an obligation of establishing transfer pricing documentation for financial transactions involving loans.
According to the Minister’s reply, while determining whether a controlled transaction involving several loans is covered by the obligation for transfer pricing documentation, the principal value of all outstanding (unpaid) loans must be considered. Only the outstanding principal amount of a loan for the given year, however, is to be taken into account.
The Minister’s response also indicates that loans must be disclosed in the transfer pricing documentation for each tax year until they are repaid (provided that the threshold of PLN 10 million is exceeded).
Read a February 2022 report prepared by the KPMG member firm in Poland
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