Amendments to transfer pricing regulations since 2019 – selected issues

Abstract

The aim of this paper is to describe the changes in the law that have taken place in the area of transfer pricing regulations starting 1 January 2019. First, the essence of the legal structure of transfer prices is presented. Then, the changes in the reclassification and omission of transactions for the purpose of transfer pricing, the catalogue of transfer price estimation and verification methods, and simplified settlement rules and changes in transfer pricing documentation are specified. The research method used in this research consists in analysis of legal acts using the literature on the subject. Based on the analysis, it may be concluded that, on the one hand, changes in the law were aimed at removing administrative burdens from taxpayers which the legislature considered unnecessary and, on the other hand, the scope of powers of tax authorities was extended and the potential severity of tax sanctions was increased.

Keywords

• transfer prices
• safe harbour
• transfer pricing documentation