New documentation obligations in transfer pricing.

Significant changes have been made in the area of transfer pricing rules. By extension of the related parties definition, the documentary obligation was introduced in case of articles of incorporation of a company which is not a legal person, joint venture agreements or contracts of a similar nature. The obligation to draw up the documentation in case of abovementioned agreements occur also when one party of the agreement is an entity with the place of residence, registered seat or have management board on the territory or a country engaged in harmful tax competition. Additionally, from January 1, 2015, the transfer pricing provisions are applicable appropriately to the Polish taxpayers conducting business activity by foreign company and to non-resident conducting business activity by the company located in Polish territory, in the transactions between these taxpayers and their foreign company, assigned to this foreign company.

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