ARTICLE · 17 JANUARY 2019

Changes In The Area Of Intercompany Transactions

Wolf Theiss

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In theory, the tax may later be refunded by tax authorities. The refund procedure has not yet been defined.

PolandTax

Karolina Stawowska

Izabela Wiewiórka

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.

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