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 new windfall tax on oil companies to lower fuel costs
Poland's government has moved forward with plans for a windfall tax (excess profit tax) on oil companies' excess
Read More
Poland advances VAT modernisation through ViDA package implementation
Poland's Council of Ministers backed a draft amendment to the Act on Goods and Services Tax and related legislation,
Read More
Poland proposes extending corporate withholding tax pay & refund suspension to 2028
Poland’s Ministry of Finance has published draft corporate income tax and personal income tax regulations for
Read More
Poland proposes CIT hike to fund energy-intensive industry support
Poland's government has advanced a draft legislative proposal (Draft Act UD459) to support energy-intensive industries
Read More
Poland proposes higher corporate tax rates in 2027 draft budget
Poland’s government has approved a draft 2027 budget on 28 August 2026 with projected total tax revenues of PLN 622.4
Read More
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