There are significant chances to eliminate the provisions on the documentation obligation in the field of “indirect tax heaven” transactions.
Let us remind you that it is about the obligation to prepare transfer pricing documentation in transactions with unrelated entities, if their beneficial owner is a “tax heaven” entity.
This regulation has been repeatedly criticized for creating unnecessary administrative obligations and excessive complexity. In practice, they force taxpayers to collect and submit numerous declarations about their status.
Currently, amendments to the CIT Act (the so-called “Polish Deal 2.0”) are being processed. Originally, the Ministry of Finance assumed the easing of the regime (inter alia, by increasing the documentation thresholds). According to the position of the Ministry of Finance published yesterday, it is expected that the provisions on the documentation obligation in the field of “indirect” paradise transactions will be eliminated from the CIT Act.
We expect this position to be translated into changes to the draft amendment act.
At the same time, we would like to remind you that the obligations in the field of 2021 have not been repealed at the moment, so it is worth taking care of their implementation. Please do not hesitate to contact us.
We will keep you updated on the status of these changes.
