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Treatment of Business Restructuring Defined for Polish Transfer Pricing Rules

25 March 2014

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Approved Changes

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Poland

Poland's Ministry of Finance has issued guidance on transfer pricing in regards to business restructuring involving related parties. The guidance is in regard to Poland's transfer pricing regulations that were issued in 2013. The main points of the guidance are as follows. For transfer pricing purposes, business restructuring is defined as the transfer of economically significant functions, assets and risks between related parties. The main aspect of which is the shift of profit potential between related parties. When evaluating the arms length compliance of business restructuring involving related parties, the following factors are analyzed by the Polish tax authorities: Economic...