Poland has published Notice No. 1105 in the Official Gazette on 21 December 2024, setting the base interest rates and margin interest rates for transfer pricing in individual and corporate income taxes.

The regulation establishes base interest rates for loans, setting a maximum margin rate of 2.6% for borrowers and a minimum margin rate of 2% for lenders, along with the underlying interest rate applicable to both.

These rates will take effect on 1 January 2025.

Earlier, Poland’s tax authority announced the base interest rates and margins for the safe harbour simplification for loan, credit, or bond transactions between related parties in 2024 on 3 January 2024.