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Poland Plans to Review its Transfer Pricing Regime

9th December 2021

Since 2015, when the OECD released a report on BEPS Actions 8 through 10, Poland has made transfer pricing legislation high priority. In 2018, the government rewrote its transfer pricing rules, including new documentation and reporting standards, which went into effect in 2019, and also, commissioned a forum to weigh in on future transfer pricing practices. And here it is 2021 and the country shows no signs of letting up on multinational companies engaging in related-party transactions. In fact, the Polish government announced a project that involves a two-year review of its transfer pricing regime. The goals? To make sure that Poland’s legislation is in line with likeminded countries (i.e. those who also view transfer pricing legislation as high priority) and to ensure that electronic reporting is working effectively. To execute the plan, Poland has picked five countries to partner with—Germany, the NetherlandsSwedenthe U.K., and the U.S.—and together, they’ll review and compare documentation obligations and the effectiveness of electronic reporting and analysis. Poland’s Ministry of Finance will determine how Poland’s current transfer pricing regulations and reporting standards stand up, and the department will train Polish tax officials in reviewing transfer pricing. What does this mean for multinational companies? So glad you asked. Well, Poland’s throwing a lot of resources into tightening the transfer pricing legislation belt, which can only mean that the Ministry of Finance will on the lookout for taxpayers who aren’t answering to it.