ALERT: Transfer pricing. Fundamental changes in documentation

On 28 April 2015, a draft amendment to the Act on Personal Income Tax and the Act on Corporate Income Tax was published on the website of the Government Centre for Legislation. On 15 June 2015, another draft amendment to the Act was published, as the original one was modified based on the comments gathered as part of public consultations and interministerial discussions. The Centre also published executive acts and form specimens taxpayers entering into transactions with affiliated entities will be obliged to submit.

The draft announces significant changes in the requirement to prepare transfer pricing documentation for transactions with affiliated entities. The proposed changes aim at reducing the group of entities obliged to prepare such documentation. However, the documentation will have to be much more extensive, and in some cases benchmark studies for transactions will also be required.

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