Poland Proposes New Transfer Pricing Rules including CbC Reporting

On 27 April 2015, the Polish government published draft measures to amend the countries transfer pricing (TP) rules, including a major change in the documentation requirements in line with requirements introduced as part of Action 13 of the OECD Base Erosion and Profit Shifting (BEPS) Project. The main changes include:

• The shareholding threshold for determining if parties are related would be increased from 5% to 20%;
• The following documentation requirements would be introduced:
  • A local file…