The Finance Ministry hosted a meeting on 18 December to seek consultation on new transfer pricing regulations coming into force in 2019. The meeting saw a numerous representation of the business world and experts from the tax consulting industry. SENDERO Tax & Legal was represented by Andrzej Jagiełło and Michał Wodzicki as our transfer pricing specialists.

The meeting was intended as a platform for the exchange of opinions and conclusions regarding the new law, especially in relation to:

  • recharacterisation and non-recognition of transactions,
  • alternative transfer pricing methods and valuation techniques,
  • safe harbours for low value adding services and loans,
  • reporting thresholds, including definition of uniform transactions,
  • transfer pricing adjustments and how they are applied,
  • identification of associations between enterprises.

During the consultations the representatives of the Ministry exhibited an open and flexible attitude as they resolved numerous concerns taxpayers have about the new regulations. The meeting is expected to give rise to the issuance of tax guidelines by the Ministry.