The MF informed that work had already been underway on the solutions already announced and expected by taxpayers regarding the possibility of obtaining a prior price agreement in a simplified procedure.
The current rules on the rules for obtaining prior price agreements lay down a fairly time-consuming and costly procedure for obtaining such an agreement, which translates into a small number of agreements concluded. The main advantage of a price agreement is to limit the risk of contesting the market price in transactions between related parties that are covered by such an agreement. In the process of obtaining such an agreement, the terms of the transaction shall be verified by the MF.
The announcements of the introduction of a simplified APA procedure to make this tool more accessible to taxpayers came more than a year ago
Simplification consists primarily of reducing fees and reducing documentation requirements (for selected transactions involving a limited risk of tax revenue impact). In line with previous announcements, the introduction of a simplified procedure will also reduce the waiting time for decisions.
According to the Communication, prior price agreements will be regulated in a single law, including the double taxation dispute resolution regulations, treats these issues as one category - tools to eliminate tax risks. To this end, a proposal for a completely new law on the settlement of disputes concerning double taxation and the conclusion of prior price agreements will be presented. The planned deadline for the adoption of the project by the Council of Ministers was set for the second quarter 2019.
https://bip.kprm.gov.pl/kpr/form/r9823740421551 ,Draft-Laws-on-solution-con-con-relationship-related-double-taxing-and-.html
Author
Leszek Dutkiewicz Partner at Russell Bedford.
From 2011 related to Russell Bedford Poland. In years 2008 – 2011 worked for leading consulting companies (Ernst&Young, KPMG, BDO) providing tax advisory services. He specializes in tax and economic law, primarily in international tax law, tax proceedings, VAT and transaction prices. Author of a publication on tax, civil and international law issues. Lecturer in tax law training. He has legal education, in 2008 graduated from the Faculty of Law and Administration of the Jagiellonian University.