Poland

Abstract

In general, Polish transfer pricing (“TP”) regulations follow the OECD Transfer Pricing Guidelines after BEPS (including the introduction of Action 13 documentation requirements into Polish rules). The arm’s length principle based on the OECD Model Tax Convention and the TP documentation standards are reflected in Polish law. There are Advance Pricing Arrangements (“APA”) available in the form of unilateral, bilateral, or multilateral agreements. The avoidance of double taxation is provided for under Mutual Agreement Procedures governed by Double Tax Agreements. Within the European Union, the EU Arbitration Convention is available for intercompany transactions.