New Polish MDR Regulation from a Transfer Pricing Perspective

The Polish Ministry of Finance has stated that, in principle, standard transfer pricing acts, such as the preparation of transfer pricing documentation and benchmarking/comparability studies, do not result in a reportable scheme, provided that those engaged in this process are dealing solely with past events. However, since advisers usually make some future recommendations in this respect, the arrangements in question will often be considered reportable. Moreover, reporting obligations may arise in connection with numerous other types of transfer pricing-related issues.