A draft bill added on 4 September 2020 to the legislative agenda includes measures that would amend the transfer pricing rules.
The proposed measures generally concern corporate income tax and individual (personal) income tax laws and would be intended to “tighten up” the Polish tax systems. There are expectations that the proposals could be passed by the Council of Ministers in the third quarter of 2020.
One of the key proposals would make the amount of tax paid by the largest entities, especially multinationals, dependent on the place where the income is actually earned. Concerning transfer pricing, the draft bill would revise the transfer pricing regime by:
Changes in the area of transfer pricing would also affect the rules that currently apply for making transfer price adjustments and also the rules regarding the Local file and the relevant declaration.
Read a September 2020 report [PDF 235 KB] prepared by the KPMG member firm in Poland
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.