Category: Transfer pricing

Business restructurings can have significant transfer pricing implications, particularly when they involve changes in functions, assets, or risks between related entities. This article outlines when a reorganization qualifies as restructuring and what documentation and reporting obligations may arise. For the purposes of transfer pricing regulations, not every business reorganization qualifies as a restructuring. At the […]

Transactions involving intangible assets, such as trademarks, patents, know-how or licences, are at the centre of interest of tax authorities. In tax practice, they constitute one of the areas with increased transfer pricing risk. This results from the difficulty in valuing such assets and from the fact that they are often used in transactions between […]

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 […]

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 […]