The Ministry of Finance has published tax clarifications on transfer prices concerning the adjustment of transfer prices within the meaning of Article 11e CIT Act (Article 23q PIT Act), as regards the provisions in force since 1 January 2019
For the adjustment of transfer prices within the meaning of Article 11e CIT Act (Article 23q The PIT Act) published below explains issues such as:
- adjustment of transfer prices in the context of the market price principle,
- adjustment of transfer prices within the meaning of Article 11e CIT Act (Article 23q PIT Act) — KCT11e,
- the conditions of the KCT11e and the consequences of their/non-compliance,
- correction of revenue or revenue costs,
Intertemporal issues.
In view of the Interpretative doubts raised by entrepreneurs against the background Article 11e The CIT Act was necessary to prepare tax explanations in this respect.
In the course of work, a compromise solution was created, taking into account not only the position of jurisprudence and the doctrines of law, but also the rations and opinions expressed by business during tax consultations.
The explanations remove many unknown companies reported by entrepreneurs and thus increase the security of companies making subsequent adjustment of transfer prices.
- Deputy Minister Jan Sarnowski.