Poland’s Government published the revised draft of the Personal Income Tax /Corporate Income Tax Act (Bill) concerning documentation of intercompany transactions on 18 June 2015. According to the revised draft, the management or control shareholding of a taxpayer qualifying as a related party for transfer pricing purposes is to increase to 25% (instead of 20% as proposed in the first draft). The revised draft provides that the tax authorities may request documentation concerning transactions or events if it is probable that the value of the transaction was intentionally reduced to avoid the documentation requirement. The time for submitting this documentation would be 30 days from the date of the request and not the standard deadline of 7 days. The first draft would have required documentation from taxpayers whose revenues or costs exceed €2 million without considering the degree of influence of the transaction on the level of income or loss. The revised draft bill will be effective from 1 January 2016 to 1 January 2017.
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