On 24 December 2021, the Polish Official Gazette published a Regulation No. 1192, establishing base interest rates and margin rates for the purposes of transfer pricing for individual and corporate income taxes. The “Safe Harbor” interest rate applies when loans are concluded between related parties. The regulation includes measures: 1) setting base interest rates for loans; 2) setting a maximum 2.8% margin rate for borrowers; 3) setting a minimum 2% margin rate for lenders; and 4) setting the value of the underlying interest rate for lenders and borrowers. The rates apply from 1 January 2022.
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