Ruling Regarding Default on Intercompany Loans: The Reason for an Income Adjustment

Journal
Author
Rzymkowska, S.
Country
Poland
Published Date
Issue
International Transfer Pricing Journal 2012 (Volume 19), No. 4
FormatPDF
EUR
45
| USD
50 (VAT excl.)

The author considers a ruling by the Lower Administrative Court in Warsaw regarding a disputed tax assessment in connection with intercompany loans which had not been settled in accordance with the relevant internal loan agreements. The case is still subject to an appeal procedure, so the conclusions of the case may change due to Supreme Administrative Court’s judgment.