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Poland Clarifies Dividend Payments Not Controlled Transactions for Transfer Pricing Documentation Purposes

11 September 2020

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Approved Changes

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Poland

Poland's Ministry of Finance has published its response to Interpellation No. 9368 from parliament on the need for transfer pricing documentation for dividend payments to related parties. The interpellation was made because the definition of controlled transactions for transfer pricing purposes is "ambiguous and covers a broad range of economic events". Given the ambiguity, two questions were put forward: Is a dividend payment to a related company subject to documentation requirements if exceeding the documentation threshold? If the answer to the first question is yes, is the threshold PLN 10 million, i.e., the threshold for financial transactions? In the response,...