On 22 March 2019, Poland’s legislative centre published a draft bill that addresses dispute resolution of double taxation issues and advance pricing agreements (APAs). Under this taxpayers will be benefited from the new procedure on Simplified Advance Pricing Agreement (sAPA) under certain conditions. “Simplified APAs” will have the unilateral nature and it will be addressed to a beneficiary.
The procedures for concluding a “simplified APA” should be completed within three months of the application. Once concluded, a “simplified APA” would apply for a maximum period of three years, with the possibility of renewal for the next three year. It is proposed that the user fee for applying for or renewing a “simplified APA” would be PLN 20,000 (approximately U.S. $5,200). If approved, the act will come into force on 1 July 2019.
