Post by account_disabled on Mar 14, 2024 8:18:45 GMT
Respectively the date on which the expenses were incurred as derived from the original document. Conditions for correction Reference is made to the prerequisites for transfer pricing adjustments in accordance with Art. Article 1 of the Enterprise Income Tax Law stipulates that adjustments can be made if the following conditions are met: Conditions set by unrelated entities are set in the controlled transactions conducted by the taxpayer during the tax year; There are changes in major circumstances that affect the conditions determined during the tax year or constitute a calculation of the transfer price The actual costs incurred or revenue earned on the basis.
Are known and ensured that they comply with the conditions set by the unrelated entity requiring adjustments to the transfer price. A statement by the taxpayer that the taxpayer has an associated entity AWB Directory at the time the adjustment is made indicating that the entity made transfers of the same amount as the taxpayer. The relevant entity mentioned in point 1 of the Pricing Adjustment has its registered office or administrative body of residence located in the territory of the Republic of Poland or is located in a country or region that has concluded a double taxation agreement with the Republic of Poland and has legal rights to exchange tax information with that country.
The underlying taxpayer recognizes transfer pricing corrections in its annual tax return for the tax year to which the correction relates. But what needs to be clearly emphasized is that in order to enable taxpayers to exercise their rightsBenefits must accumulate to meet these conditions. Of course, parties to a transaction are obliged to meet the primary requirement of adhering to the arm's length principle in their relationships with related entities. From a transfer price perspective, situations that are significant and cannot be predicted when planning transfer prices for the year include, for example, significant changes in the market prices of underlying.
Are known and ensured that they comply with the conditions set by the unrelated entity requiring adjustments to the transfer price. A statement by the taxpayer that the taxpayer has an associated entity AWB Directory at the time the adjustment is made indicating that the entity made transfers of the same amount as the taxpayer. The relevant entity mentioned in point 1 of the Pricing Adjustment has its registered office or administrative body of residence located in the territory of the Republic of Poland or is located in a country or region that has concluded a double taxation agreement with the Republic of Poland and has legal rights to exchange tax information with that country.
The underlying taxpayer recognizes transfer pricing corrections in its annual tax return for the tax year to which the correction relates. But what needs to be clearly emphasized is that in order to enable taxpayers to exercise their rightsBenefits must accumulate to meet these conditions. Of course, parties to a transaction are obliged to meet the primary requirement of adhering to the arm's length principle in their relationships with related entities. From a transfer price perspective, situations that are significant and cannot be predicted when planning transfer prices for the year include, for example, significant changes in the market prices of underlying.
