On 29 December 2023, Poland’s Ministry of Finance released the guide on submitting transfer pricing information, which includes:
- Detailed FAQs related to the obligation to submit transfer pricing information;
- entity identification details;
- place and purpose of submission;
- benchmarking studies;
- transaction-related specifics ( i.e., transaction value, transfer price adjustments);
- individual transaction categories.
Base interest rates and margin rates
The guide also includes a Notice published on 27 December 2023, which introduces the base interest rates and margin rates for transfer pricing concerning personal and corporate income tax—effective 1 January 2024.
The Notice specifies the type of base interest rate and required margin to determine the interest rate on loans, credits, or bonds.
The use of base interest rates based on the LIBOR USD 3 months and LIBOR GBP 3 months benchmarks for contracts priced in USD or GBP before 1 January 2022 has been approved.
It should be noted that the USD 3-month LIBOR will be phased out by the end of September 2024, and the GBP 3-month LIBOR will be withdrawn by the end of March 2024.
