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Poland Proposes New Transfer Pricing Rules including CbC Reporting

08 May 2015

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Proposed Changes

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Poland

On 27 April 2015, the Polish government published draft measures to amend the countries transfer pricing (TP) rules, including a major change in the documentation requirements in line with requirements introduced as part of Action 13 of the OECD Base Erosion and Profit Shifting (BEPS) Project. The main changes include: The shareholding threshold for determining if parties are related would be increased from 5% to 20%; The following documentation requirements would be introduced: A local file detailing related party transactions involving the local entity and other information; A benchmarking study if annual revenue or costs exceeding EUR 10 million; A...