On 24 March 2023, the Polish Ministry of Finance published guidance clarifying the application of the resale price method to determine the arm’s length value of transactions between related parties. The guidance focuses on practical aspects of using this method, including criteria for transaction and entity comparability, potential difficulties and errors in using the RPM, and a comparison with other transfer pricing methods.
The guidelines apply to controlled transactions that fall under the provisions of the Corporate Income Tax Act and the Income Tax Act and are conducted after 31 December 2018.
