Poland: Transfer pricing measures in legislation amending “Polish Deal”

Legislation amending corporate income tax provisions enacted as part of the “Polish Deal” includes transfer pricing-related measures

Transfer pricing measures in legislation amending “Polish Deal”

The Lower House of the Polish Parliament (the Sejm) passed legislation amending corporate income tax provisions enacted as part of the “Polish Deal” that includes the following transfer pricing-related measures:

  • Amendments to the provisions relating to requiring Local files for tax haven transactions
  • Changes to rules relating to obligation of entities required to submit transfer pricing reports to provide head office with information on contracts with non-residents

The legislation now must be signed by the president, and the amendments would become effective 1 January 2023—except for provisions relating to requiring Local files for tax haven transactions, which would become effective as of the day of announcement. 

Background

  • The Polish Deal refers to legislation amending the income tax laws affecting corporations and individuals, as well as the value added tax (VAT) and other tax legislation, which was passed on 29 October 2021 and is generally effective as of 1 January 2022. Read TaxNewsFlash
  • The government on 28 June 2022 published proposed legislation that included amendments to the Polish Deal corporate income tax provisions. Read TaxNewsFlash
  • A draft bill including amendments to the Polish Deal corporate income tax provisions was submitted on 25 August 2022 before the Sejm. Read TaxNewsFlash

Read an October 2022 report prepared by the KPMG member firm in Poland

 

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