Published : 2022-03-30

Transfer Pricing and Local File Documentation from the Perspective of Tax Law

Aleksandra Sówka



Abstract

Transfer pricing is an important issue for related companies and their accounting. Capital groups use transfer pricing to share revenue or as a form of control. However, tax authorities have recognised the risk of related companies using transfer pricing for tax avoidance. Therefore, the topic of transfer pricing is inextricably linked to the Arm's Length Principle and the market value of transactions as such. To counteract possible tax avoidance, rules have been established to control transactions that may lead to such abuse, both domestically and internationally. The objective of the case study described in the article is to demonstrate that transactions between affiliated entities, and more specifically the sale of programming services by ABC PL to its parent company was made according to the Arm's Length Principle. The transfer pricing applied in the transactions made in 2020 was analysed by accounting for applicable regulations, including changes introduced in 2019 by the amendment of the Corporate Income Tax Act.(original abstract)

Keywords:

Transfer pricing, Comparative analysis, Corporate income tax



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Sówka, A. (2022). Transfer Pricing and Local File Documentation from the Perspective of Tax Law. Zeszyty Naukowe Wyższej Szkoły Bankowej W Poznaniu, 96(1). https://doi.org/10.5604/013001.0016.0362

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Publisher
Uniwersytet WSB Merito w Poznaniu
ul. Powstańców Wielkopolskich 5
61-895 Poznań
e-mail: journals@poznan.merito.pl
University
Uniwersytet WSB Merito w Poznaniu / WSB Merito University
ul. Powstańców Wielkopolskich 5
61-895 Poznań

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