The Ministry of Finance has published tax explanations on the method of comparable uncontrolled price, with regard to the provisions in force since 1 January 2019
As regards the method of comparable uncontrolled price, the following explanations cover:
- the conditions for applying the comparable uncontrolled price method,
- options for a comparable uncontrolled price method,
- comparison of the method of comparable uncontrolled price with other methods,
- typical areas of application of the comparable uncontrolled price method,
- difficulties in applying the comparable uncontrolled price method,
- an example of the use of a comparable uncontrolled price method.
The Ministry of Finance, in order to clarify the practical aspects related to the application of the comparable non-controlled price method and to increase tax security for taxpayers, has undertaken the work resulting in these tax explanations explaining the methodology of application one Transfer pricing verification methods. The explanations were created taking into account the recommendations of the Transfer Pricing Forum dated 11 June 2019 concerning the description of the comparable non-controlled price method (PCN).
- indicated Deputy Minister Jan Sarnowski.
Explanations in the pdf can be downloaded below.