Poland has published changes to its blacklist, which are effective 19 May 2015. The changes include the removal of six jurisdictions from the list:
The main effect of removal is that companies in these jurisdictions will no longer be automatically considered CFCs under Poland's CFC regime. In addition, when a company in these jurisdictions is otherwise deemed to be a CFC under the standard rules, the CFC income attributed to the taxpayer is prorated based on the period during the year the CFC is controlled instead of the CFC income for the whole year.
Removal from the list also affects transfer pricing documentation requirements. The transaction amount threshold for preparing transfer pricing documentation in relation to companies in these jurisdictions is no longer EUR 20,000, but is instead EUR 30,000, EUR 50,000 or EUR 100,000 depending on the transaction type.
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