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New Transfer Pricing legislation in Poland regarding resolution of disputes and APAs

There is new Transfer Pricing legislation in Poland. The so-called DRM Act was signed on 5th November and relates to:

  • The resolution of disputes regarding double taxation; and
  • the conclusion of Advance Pricing Agreements.

 

Key highlights

  • Costs regarding the purchase of intangible services from related parties are fully deductible if the APA confirms the way of calculation (otherwise some costs may not be tax deductible).
    • Timing:
      If you submit your APA request before 31st December 2019, you can still obtain the full tax deductible for the fiscal year 2018 and fiscal year 2019.
  • The original provisions on the simplified APA procedure are separated from the DRM Act and not yet published.
  • Due to the distant (and successively lengthening) deadlines for the examination of requests submitted by taxpayers, it is difficult to indicate the time limit for the conclusion of an APA.