Poland’s Ministry of Finance proposed changes on 11 June 2013 that might amend the provisions concerning advance pricing agreements (APAs) if sanctioned.
Changes in the APA – Extended the scope of transactions to APAs by repealing current law provisions that limit an APA to one type of transaction between the related parties; Review the required items to be included in an APA; allow for retroactive application of an APA. Generally the effect of the measures is to give the taxpayer greater scope to enter into an APA with the tax authorities. There may also be some concern among taxpayers as to the implications if the tax authorities are able to indicate the reasons why an APA was annulled.
