What Poland permits when calculating income
July 14, 2008
Jaroslaw Bieronski and Bartlomiej Bialy of Soltysinski Kawecki & Szlezak highlight the transfer pricing methods allowed in Poland
The Polish Corporate Income Tax Act (CITA) demands that every transaction between related parties has to be at arm's-length. Otherwise the tax authorities may apply certain methods to determine whether payments made under such transactions are arm's-ength. According to Article 11 of the CITA the tax authorities may estimate income according to the methods referred to in the legislation. Detailed conditions for applying such methods are specified in the Minister of Finance Decree of October 10 1997. One of the following methods may be used for the income estimation:
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