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.
- 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).
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.