Restrictions and delays hamper Polish APA programme
February 14, 2008
Artur Klesk, head of transfer pricing at Accreo Taxand, a leading Polish TP commentator, discusses the fortunes of the APA initiative
Prior to 2006, there were no legal mechanisms in place in Poland to avoid transfer pricing disputes. At the same time, the tax authority regularly conducted time-consuming and costly tax audits. No legally binding institution existed which allowed taxpayers to arrive at an advance agreement with the tax authorities on the selection of the pricing methods used in transactions with related parties and their application in the specific cases (including the market range and arm’s length level of charges used).
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