Transfer pricing and transactions involving a beneficial owner from a tax haven
February 2022
As of January 1, 2021, regulations for so-called indirect tax haven transactions are in effect. These apply to
transactions where a receivable is transferred to a ‘beneficial owner’ who is domiciled, established or managed in a tax haven.
The lawmakers imposed a documentation obligation on taxpayers, applicable to indirect tax haven transactions with a value exceeding PLN 500,000. This means that it will be necessary to include them in local transfer pricing documentation (local file) for 2021 and subsequent tax years, if such an obligation has been identified. The deadline for preparing documentation for the 2021 tax year, and, consequently, for filing transfer pricing information (TPR), is September 30, 2022.