Advance Pricing Agreement Polska

The new provisions of the “October 16, 2019 Double Taxation Dispute Resolution Act and the implementation of prior price agreements (the “law”) amend and strengthen the rules for implementing the APA and the dual taxation dispute resolution procedures in a single legal instrument. 1% of the value of the transaction that is the subject of the agreement. In the case of: It should be noted that the amendments introduced in 2018 have limited, for many taxpayers, the right to fully deduct tax costs. B, including acquiring intangible services, to related companies and thus increasing their base. Only subjects who signed advance price agreements were exempt from the above restrictions. As a result, taxpayers were waiting for a simplified APA procedure act (as announced by the Department of Finance) that would be relatively quick and inexpensive. Procedures under the arbitration agreement (only with respect to transfer pricing); and for the first time in Poland, the law also provides for the possibility of concluding a cooperation agreement with the head of the national tax administration (horizontal monitoring solution). This applies to taxpayers whose revenues exceeded EUR 50 million in the past financial year. On the one hand, the implementation of a cooperation agreement with the head of the national tax administration implies that it must submit to a tax check and, on the other hand, the subject would benefit from several advantages such as: a new procedure for improving and standardising the rules for setting double taxation in the European Union would relate to double taxation disputes related to the interpretation and application of agreements and conventions to abolish income taxation if Poland and other EU countries are involved. The measures in the bill would make it easier for individuals and small and medium-sized enterprises (SMEs) and micro-enterprises to access within the meaning of the directive. On 22 March 2019, a draft law on the settlement of disputes concerning double taxation issues and pre-price agreements (APAs) was published on the website of the Polish Legislative Centre.