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Wojciech Marszałkowski

Transfer pricing: The next amendment
A revised bill to amend tax regulations as part of the “Polish Deal” has been submitted to the parliament. How do the proposals involving transfer pricing look now?
Transfer pricing: The next amendment
Proposed changes in transfer pricing regulations
Transfer pricing regulations have been included in the package of proposed changes to tax law implementing the political programme known as the Polish Deal. Some of these changes respond to market expectations and deserve applause. Others will complicate taxpayers’ lives. Here we examine the proposed solutions.
Proposed changes in transfer pricing regulations
Benefits for people returning from abroad, tax holidaymakers, and tax optimisers coming in from the cold
A comprehensive overhaul of Polish tax law is expected. The proposed changes would implement the Law & Justice government’s programme known as the “Polish Deal.” Some of these changes are intended to make the tax system more attractive to new taxpayers. Others are designed to encourage taxpayers who have used optimisation schemes in the past to put their tax affairs in order.
Benefits for people returning from abroad, tax holidaymakers, and tax optimisers coming in from the cold
Tax strategy: A step toward transparency or just more red tape?
Tax strategy: A step toward transparency or just more red tape?
Despite the difficulties this year, Polish lawmakers did not forget about their annual update of tax laws. Under the recently adopted regulations, the Treasury will seek to learn more about taxpayers by requiring them to draft, file and even publish a tax strategy. Is this a move toward transparency for the country’s largest companies, or another unnecessary formality?
Tax strategy: A step toward transparency or just more red tape?
Transfer pricing documentation is not usually required for domestic transactions—but sometimes it is
Transactions between related parties at a value above statutory thresholds must be identified in local transfer pricing documentation, but the regulations provide for a number of exceptions.
Transfer pricing documentation is not usually required for domestic transactions—but sometimes it is
Tax interpretations on the obligation to prepare transfer pricing documentation
Although the definition of a “controlled transaction” has been introduced into the PIT Act and the CIT Act, taxpayers (and lawmakers) still have doubts which events require preparation of transfer pricing documentation. Today, we write about transfer pricing documentation in the case of contributions to share capital, share redemptions, and dividends.
Tax interpretations on the obligation to prepare transfer pricing documentation
Transfer prices: You can never be too sure when making an adjustment
Adjustments of transfer prices have generated a lot of uncertainty among taxpayers for a long time, as evidenced by the large number of individual tax interpretations issued in this area. Due to the change in regulations, and because the right to make an adjustment is affected by numerous factors, taxpayers seek interpretations from the revenue administration even when the facts are not very complicated.
Transfer prices: You can never be too sure when making an adjustment
Extension of deadlines to perform transfer pricing obligations
“Shield 4.0” extends the deadlines for all obligated entities to file transfer pricing information (TPR), declarations on preparation of local transfer pricing documentation, and enclosures of group transfer pricing documentation. The earlier regulations extended the deadlines only for selected taxpayers.
Extension of deadlines to perform transfer pricing obligations
The Ministry of Finance is open to comments and suggestions on the Cooperation Programme
Recently we wrote about the planned implementation of the Cooperation Programme, under which selected taxpayers would be given the opportunity to cooperate with the head of the National Treasury Administration on a permanent basis. This cooperation would, among other things, enables taxpayers to reach decisions on tax strategy in consultation with the authority competent for verifying the correctness of the taxpayer’s settlements. Until 26 May 2020, taxpayers may submit comments and suggestions to the Ministry of Finance on selected documents relevant to the programme.
The Ministry of Finance is open to comments and suggestions on the Cooperation Programme
Draft tax guidelines: Rules for collection of withholding tax
The Ministry of Finance has published a draft of the long-awaited clarifications of the rules for collection of withholding tax and the obligations of tax remitters. The document is intended to resolve taxpayers’ doubts arising after amendment of income tax acts.
Draft tax guidelines: Rules for collection of withholding tax
Costly parting of the ways with the Polish tax authorities: Tax on income from unrealised gains
A tax amendment is lying on the Polish President’s desk. It will introduce, among other things, a tax on income from unrealised gains. As announced, the regulations should enter into force at the beginning of 2019.
Costly parting of the ways with the Polish tax authorities: Tax on income from unrealised gains
Split payment mechanism: Apparent and hidden benefits
Businesses are not required to use the split payment mechanism. But the initiative left to them does force them to examine whether it would be worthwhile to take advantage of this new instrument. Lawmakers went to some effort to encourage taxpayers to say yes.
Split payment mechanism: Apparent and hidden benefits