Transfer pricing - important changes from the 1st of January 2017

The modification of the definition of related parties

Related parties are considered only those whose share in the capital of another company is not smaller than 25%, and not as it was before: only 5%.

New rules for transfer pricing documentation

The documentation will contain:

• transactions with related parties
• other events included in the books in a given fiscal year with a significant impact on income (loss) of the taxpayer

carried out by the taxpayer in the fiscal year in question.

The requirement for documentation depends on:

•   the amount of revenues and expenses in accordance with accounting rules, generated by the taxpayer in the previous fiscal year and determined on the basis of accounting kept;
• the excess of the thresholds of the value of transactions/ events of one type, determined according to the revenues.