Authors: Paula Arciszewska, Aleksandra Chojnacka, Tomasz Hopej, Sylwia Imiela, Kamil Jaśkiewicz,Justyna Kołodziejczyk, Jarosław Mika (redaktor naukowy), Karolina Ostapiuk, Beata Rawa, Paweł Rosiński, Piotr Rzepka, Maciej Samuła
Year of publication: 2018
Number of pages: 624
ISBN: 978-83-8124-998-0
Date of publication: October 2018
The book contains an overview of the most common types of transactions and events taking place in capital groups, with particular emphasis on specific transactions, such as: cash pooling, contract manufacturing, business restructuring, guarantees / sureties, and license fees.
The publication presents transfer pricing issues valid until December 31, 2016 and new regulations implemented after January 1, 2017, including:
- grouping transactions,
- definition of transactions and events of one type,
- determining revenues for the year preceding the tax year,
- description of compliance of transaction conditions.
In addition, the paper presents a methodology for preparing comparative data analysis and discusses the databases used for analysis. The most frequent tax risks that may arise during tax / customs-tax audits are indicated. A number of individual tax interpretations and judicial decisions of administrative courts were referred to.
The authors also presented exemplary tax documentation for the country.
The study describes the duties of the so-called tax reporting including simplified CIT-TP / PIT-TP form. The subject of considerations are also issues related to fiscal penal liability of individuals and collective entities subject to reporting obligations in the field of transfer pricing. The issues of the double taxation clause including adjustments of tax liabilities under the mutual communication procedure (MAP) were also discussed.
The publication is intended for tax advisors, lawyers, legal advisors, judges as well as statutory auditors and auditors. It will be a valuable source of knowledge for employees of tax / customs-tax administration, economists and accountants, managers of various levels and entrepreneurs.