Poland: Applications for APA to be submitted until the end of the year


published on 6 August 2020  


Anyone wishing to apply for an Advanced Pricing Agreement (APA) concerning a controlled transaction carried out in 2020 should do it until the end of this year.

Documentation obligations in the context of APA

The anti-crisis legislation package called "Shield 4.0" has extended most deadlines for the fulfilment of TP documentation obligations until the end of this year. The year-end is also the deadline for applications for Advanced Pricing Agreements on controlled transactions carried out in 2020. If you are interested in obtaining an APA, it is advisable to prepare transfer pricing documentation first because you will need a lot of information from there to apply for an APA.

What is an APA?

An Advanced Pricing Agreement is an official administrative decision which confirms that your controlled transaction complies with the arm's length principle. The decision is issued at the end of a procedure initiated at your request. The agreement is made for maximum 5 years but may be renewed.

What does an APA give you?

An Advanced Pricing Agreement in the form of an official administrative decision offers you a number of benefits. First, if an APA covers a certain transaction made in a certain year, you no longer have to prepare the transfer pricing documentation of that transaction for that year. Second, the agreement lets you deduct from tax certain expenses whose tax-deductibility is otherwise limited by Article 15e of the Corporate Income Tax Act.


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