Advance pricing agreements are worth the effort. Many businesses may see their tax bill increase after the law has limited the tax deductibility of amounts paid as royalties or fees for intangible services. The limit is currently PLN 3M per year. For businesses that are part of corporate groups and use intercompany intangibles or services, this may mean substantial increases in taxation. Large expenses which used to be deductible before may now well have to be left out of the tax calculation. The new law will hit mostly those running at relative low operating margins, such as distributors, limited-function manufacturers, etc.
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