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

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

Corporate groups commonly use intragroup guarantees to improve creditworthiness and secure favorable financing terms, but this practice carries significant tax implications under Polish transfer pricing regulations. When guarantees are provided free of charge or on non-equivalent terms between related parties, companies face risks including transfer pricing adjustments, additional tax liabilities of up to 20%, and taxation of gratuitous benefits. Understanding documentation thresholds, valuation methods, an