Poland has prepared guidance on some questions arising from the issue of transfer pricing regulations last year. The guidance is generally based on OECD principles. Under the guidance the expression “business restructuring” is defined as the transfer of significant economic functions, risks and assets from one related party to another. The guidance indicates that not every such transaction amounts to a restructuring, but the tax authorities should consider whether there has been a transfer of profit potential. Where profit potential has been shifted from one party to another the terms of the restructuring must be in line with the arm’s length principle.
Related Posts
Poland proposes 22% CIT rate for large companies in tax reform package
Poland’s government has unveiled a package of tax changes that would increase the basic CIT rate to 22% for entities
Read More
Poland expands tonnage tax regime to boost shipping under national flag
Poland has published the Act of 17 July 2026 amending certain laws to support shipping enterprises and create
Read More
Poland temporarily cuts VAT rate on motor fuels to 8%
Poland’s Minister of Finance and Economy issued a regulation on 13 August 2026 temporarily reducing the VAT rate on
Read More
Poland: Ministry of Digital Affairs unveils draft 3% digital services tax
Poland's Ministry of Digital Affairs has published a draft bill introducing a Compensatory Tax on Certain Services,
Read More
Poland: Sejm introduces new VAT warehousing regime, tightens abuse rules
Poland’s Sejm (lower house of the parliament) has enacted the draft law of 17 July 2026, which introduces a
Read More
Poland eases transfer pricing compliance, payment penalties
The Polish Council of Ministers approved amendments to the Personal Income Tax Act and Corporate Income Tax Act on 21
Read More