Category: Transfer pricing

Actions Against Aggressive Tax Optimization – Transfer Pricing

Natalia Chwała

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The Ministry of Finance is intensifying its efforts against aggressive tax avoidance and the shifting of profits abroad. During a press briefing on July 31, 2025, the Minister of Finance and Economy, Andrzej Domański, together with the Head of the National Revenue Administration (KAS), Marcin Łoboda, presented the achievements to date as well as new […]

Guarantee without remuneration – a transfer pricing perspective

Natalia Chwała

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Intra-group guarantees can significantly facilitate obtaining external debt financing or entering into contracts. This instrument is widely used but still raises questions relating to the transfer pricing.   Can a guarantee be provided free of charge? According to the 2020 OECD Guidelines on Transfer Pricing for Financial Transactions, it is not justified in every case […]