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Poland: Guidance on obligation to submit transfer pricing information, base interest rates and margin rates

The Ministry of Finance published transfer pricing guidance

January 8, 2024

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 LIBOR USD 3 months will be withdrawn at the end of September 2024, while LIBOR GBP 3 months will be discontinued at the end of March 2024.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

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