Transfer Pricing Rules Apply in Poland Deferred-Tax Cases

A company opting for Poland’s deferred corporate income tax regime remains fully subject to transfer pricing rules, the Polish Supreme Administrative Court ruled.

The Tuesday judgment, dismissing the company’s appeal against a 2023 ruling of the Voivodship Administrative Court in Poznań, is final.

Identified only as M. sp. z o.o., the company argued the deferred tax regime implied an exemption from transfer pricing documentation rules due to lack of explicit instructions in the law. It claimed exemption from Local File requirements and rules for corresponding adjustments.

Local File details local related-party transactions, while corresponding ...