The current international health emergency is having a huge impact in every area, including tax, and will foreseeably have lasting effects. Transfer pricing is not immune to this situation and its consequences are being felt in elements such as intra-group financing, how controlled transactions are carried out, priced and documented, or the advance pricing agreements concluded with the tax authorities.
Law no.119/2019, 18 September, was officially published, which amends, among others, the transfer pricing regime, namely articles 63, 130 and 138 of the Corporate Income Tax (“CIT”) Code, which establish the transfer pricing regime, the tax file obligations and the advance pricing agreements.
As of January 1, 2019, several amendments to Polish tax law are expected. Transfer pricing is subject to a number of new regulations which will apply to profits (losses) earned starting on January 1, 2019. The details of those amendments are as follows.