A significant amendment to the Corporate Income Tax
(CIT) and Personal Income Tax (PIT) laws in Poland has come into
force on 1 January 2019, which will bring rules related to transfer
pricing in line with updated OECD guidelines and the OECD's
Action Plan on BEPS.
The newly introduced changes are partly beneficial for
taxpayers:
- Under certain conditions, in relation to low value-added
services or intercompany loans with a principal of up to PLN 20
million (approximately EUR 4.8 million), the tax authorities are no
longer entitled to assess income in intercompany transactions. The
introduction of this "safe harbour" concept will simplify
intra-group settlements, in particular in the areas of accounting,
HR, and IT.
