On 12th April 2018, we had a an opportunity to participate in the first Transfer Pricing Forum organized under the auspices of the Polish Ministry of Finance.
Purpose of this Forum is to create a platform for discussion on transfer pricing – between tax administration, business, advisory and scientific communities.
The most important topics that have been discussed, were:
- Benchmarking analyses;
- Simplified advanced pricing agreement (APA) , there is a special team dedicated to APA in the Polish Ministry of Finance, some details of procedure are already disclosed by the authorities:
– decision will be in force for a period up to 3 years with extension possibility (in comparison to standard APA – 5 years);
– will be applied i.a. to low value adding services;
– fee will be smaller than for standard APA;
– summons for simplified APA will be covered by fiscal confidentiality.
- low value added services – the Ministry of Finance have been working on so called safe harbors – examples of situations in which approach presented by tax payers in the field of TP shall not be questioned.
The Forum was a great occasion to meet with representatives of the Polish Ministry of Finance to talk on transfer pricing. We will participate in the following meetings and inform on their outcomes.
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