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Poland Revises Proposed Transfer Pricing Documentation Rules

30 June 2015

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Proposed Changes

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Poland

Following a public consultation held in May, Poland has revised its proposed transfer pricing (TP) documentation rules. Two key changes from the previous draft include: The shareholding threshold for determining if parties are related would be increased from 5% to 25%, instead of 20% as previously proposed; and The entry into force date is delayed one year, from 1 January 2016 to 1 January 2017 In addition, a new transaction value based threshold is included in the draft rules. The EUR 2 million total annual revenue/costs threshold remains, but a company exceeding that revenue/cost threshold may still be outside the...