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Transfer pricing requirements – online verifier


The TP requirements – online verifier is a tool developed in-house by the tax experts from the Crido Taxand’s Transfer Pricing Team. It presents the new TP documentation requirements in a simple and user-friendly manner. All you need to do in order to find out what are the transfer pricing documentation requirements and documentation thresholds being in force as of 2017 in each of the examined cases, is answer 7 brief questions.

CRIDO TAXAND – Top transfer pricing specialist on the market

1. Is your Company an entity commencing its business activities?

As taxpayers commencing their business activities shall not be considered entities established (i) as a result of a transformation, merger or spin-off or (ii) as a result of transformation of a company which was not a legal person or (iii) by natural persons, who made a contribution to the capital of the newly established entity in the form of an enterprise (previously operated by such persons) or the assets of such an enterprise of the total value exceeding the equivalent in PLN of at least EUR 10 000.


2. Please indicate the revenue earned during the fiscal year, as determined on the basis of the accounting books (in PLN).

2. Revenue earned during the year preceding the fiscal year, as determined on the basis of the accounting books (in PLN).

3. Please indicate the costs incurred during the fiscal year, as determined on the basis of the books of account (in PLN).

3. Costs incurred during the year preceding the fiscal year, as determined on the basis of the books of account (in PLN)

4. Please indicate the average EUR/PLN exchange rate announced by the National Bank of Poland, valid on the last day of the fiscal year preceding the fiscal year to which the tax documentation refers.

5. Has the taxpayer concluded transactions / other events with ‘tax haven entities’ (entities with their place of residence, registered office or management in a country applying harmful tax competition), including joint venture agreements, articles of association as well as other agreements of a similar nature?


6. Has the taxpayer concluded articles of association of a company which is not a legal person?


7. Has the taxpayer concluded a joint venture agreement or an agreement of a similar nature?


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Thank you for using the TP requirements – online verifier. Please find below the result of the simulation of your new transfer pricing documentation requirements determined on the basis of your answers.

Should you have any further questions or require more comprehensive analysis of the flows and relationships between entities belonging to the group, please do not hesitate to contact us directly. Prior analysis often allows not only to limit the administrative obligations but also to manage the risk of disclosure of company’s sensitive information, which may not necessarily be subject to the new requirements*.

Documentation thresholds

The Scope of requirements (the value threshold criterion)
1. Transfer pricing documentation for transactions / other events exceeding the documentation thresholds (Local File) – Art. 9a sec. 1-1e, sec. 2b of the CIT Act
2. Statement confirming the preparation of tax documentation by the deadline specified for submission of the annual tax return – Art. 9a sec. 7 of the CIT Act
3. Benchmarking analysis for transactions / other events exceeding the documentation thresholds – Art. 9 sec. 2b-2c of the CIT Act
4. Simplified report on the execution of transactions / other events occurring between the related entities (CIT-TP) – Art. 27 sec. 5 of the CIT Act
(NOTE: simulation made based on the data from the previous tax year. The obligation for CIT-TP arises when in the given tax year revenue or costs exceed EUR 10 million).
5. Master File – Art. 9a sec. 2d of the CIT Act

Explanations
+ – Requirements arise
– No requirements

This report is provided for reference purposes only and does not constitute legal or tax advice. Crido Taxand assumes no responsibility for the User’s reliance on the results of the simulation without seeking professional tax advice at first.

Send the simulation results to your e-mail.

Find out more about Crido Taxand’s Transfer Pricing Team
Contact us using the contact form or by telephone: 22 324 59 00

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* – Please note that our tool does not cover requirements related to the country-by-country reporting.

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