ARTICLE · 14 MAY 2025

Changes In Safe Harbour For Loans: Poland's Transfer Pricing In 2025

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The Polish Ministry of Finance has announced updates to the safe harbour rules for loan transactions in 2025, introducing changes...

PolandTax

The Polish Ministry of Finance has announced updates to the safe harbour rules for loan transactions in 2025, introducing changes to reference margins:

For borrowers: The maximum margin is now 2.6% (down from 3.1%).
For lenders: The minimum margin is now 2.0% (down from 2.2%).

What Is Safe Harbour for Financial Transactions?

Safe harbour rules simplify compliance for certain financial transactions, like loans between related parties, by setting predetermined margins that meet the arm's length principle. This reduces the burden of transfer pricing documentation and minimizes the risk of disputes with tax authorities.

Benefits of Using Safe Harbour

Simplified Compliance: No need for complex benchmarking studies or detailed documentation.

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