Transfer Pricing Guidelines in Poland

The Minister of Finance has recently issued his interpretation of transfer pricing guidelines, based on the 1995 OECD report entitled 'Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations'. This was issued in order to bring Polish tax regulations in line with OECD requirements.

The general rule is that a price charged between two parties should be established at market rates. The directive especially relates to the prices charged in international transactions between related parties. In order to control the prices, the tax authorities and treasury control authorities may investigate whether the income generated from dealings with related parties was properly declared.