Post by account_disabled on Mar 15, 2024 23:32:20 GMT -6
Summary, in the above circumstances it is not necessary to include a comparative analysis or a compliance analysis in the transfer pricing documentation but from a pragmatic perspective it is recommended to include them. Transfer Pricing Adjustments The obligation to communicate transfer pricing adjustments in the annual tax return has been waived. This makes it easier to meet the formal conditions for effective correction. In addition, the possibility of making an adjustment increases where the taxpayer making the adjustment has accounting documentation confirming that a related entity has made a transfer pricing adjustment of the same amount.
So far the bill only explicitly states that such entities own claims. In addition, the legislator simplified the requirements related to the place of residence, registered office or management board of the relevant entity. Poland AWB Directory no longer needs to sign a double taxation agreement with the registered office or management board in the country of residence of the relevant entity. Summary The transfer pricing changes introduced in the Poland Order have both positive and negative aspects. The extension and reduction of taxpayer obligations are to be commended. Despite attempts to clarify definitions, interpretive doubts about transfer pricing have not gone away.
In some respects have become more intense. Negative consequences for taxpayers include, inter alia, a decrease in the number of inspections carried out by the tax office within the scope of fiscal criminal responsibility, which fell by almost a quarter compared to the previous year. The number of customs and tax inspections has also been significantly reduced. The coronavirus pandemic has undoubtedly had an impact on these changes. However, there is a need to consider improvements in the effectiveness of office analysis and control activities. Increasingly, inspection selection is based on risk analysis and the use of advanced analytical tools.
So far the bill only explicitly states that such entities own claims. In addition, the legislator simplified the requirements related to the place of residence, registered office or management board of the relevant entity. Poland AWB Directory no longer needs to sign a double taxation agreement with the registered office or management board in the country of residence of the relevant entity. Summary The transfer pricing changes introduced in the Poland Order have both positive and negative aspects. The extension and reduction of taxpayer obligations are to be commended. Despite attempts to clarify definitions, interpretive doubts about transfer pricing have not gone away.
In some respects have become more intense. Negative consequences for taxpayers include, inter alia, a decrease in the number of inspections carried out by the tax office within the scope of fiscal criminal responsibility, which fell by almost a quarter compared to the previous year. The number of customs and tax inspections has also been significantly reduced. The coronavirus pandemic has undoubtedly had an impact on these changes. However, there is a need to consider improvements in the effectiveness of office analysis and control activities. Increasingly, inspection selection is based on risk analysis and the use of advanced analytical tools.