Poland: Guidance on obligation to submit transfer pricing information, base interest rates and margin rates
The Ministry of Finance published transfer pricing guidance
The Ministry of Finance published transfer pricing guidance
The Ministry of Finance on 29 December 2023 published the following transfer pricing guidance:
- Updated transfer pricing guidebook that includes questions and answers concerning the obligation to submit transfer pricing information, including the place and purpose of submission, identification details and additional data of the entity to which the information relates, and transaction details (i.e., transaction value, transfer price adjustments, benchmarking studies and individual transaction categories).
- Notice (dated 27 December 2023) establishing effective 1 January 2024 base interest rates and margin rates for the purposes of transfer pricing for individual (personal) and corporate income tax, including the type of base interest rate and the amount of margin required to determine the interest rate on a loan, credit, or bond concluded between related parties. In addition, for contracts made in U.S. dollars or pounds sterling before 1 January 2022, further use of the base interest rate based on the LIBOR USD 3 months and LIBOR GBP 3 months benchmarks was approved. LIBOR USD 3 months will be withdrawn at the end of September 2024, while LIBOR GBP 3 months will be discontinued at the end of March 2024.
Read a January 2024 report prepared by the KPMG member firm in Poland
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.