Crido Sp. z o.o.
ul. Grzybowska 5A
phone: +48 (22) 324 59 00
fax: +48 (22) 324 59 01
Last Thursday (April, 12th) the First Transfer Pricing Forum organized by the Ministry of Finance took place. The TP Forum was a gathering of representatives from tax administration, advisory, business and scientific communities to exchange comments and ideas on recent changes in transfer pricing regulations. The key topic on the agenda was the formal and practical approach toward benchmarking analyses, however other related topics were also raised, including the long-awaited plans of the Ministry of Finance to introduce simplified advanced pricing arrangements’ regulations (simplified APA).
As a reminder, the simplified APA is supposed to be a legal / formal tool that, when used by a taxpayer, allows for full tax deductibility of I/C service charges (instead of the limitation introduced from 2018*). So far there were only announcements without any details presented to the taxpayers, who for the past 3,5 months were forced to adhere to the unfavorable rules.
Here are the key information on the planned simplified APA regulations:
Once the draft regulations are published, we will let you know.
* the new corporate tax regulations in Poland limit the tax deductibility of intra-group services and royalties significantly up to 5% of tax EBITDA over PLN 3m