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Transfer pricing – not all transactions have to be documented


​Dominika Tyczka-Szyda, Daria Walkowiak-Dobner

27 February 2024

Businesses affected by transfer pricing laws should check their transactions with associated enterprises carefully. This is because it may turn out that some of their controlled transactions need not be documented. 

Who can benefit from the safe harbour regime?

Taxpayers who meet certain statutory criteria may benefit from the safe harbour regime in respect of low value added services and some financial transactions – loans and bonds. 

The lawmakers have described in detail the terms and conditions of the safe harbour scheme. The key is to check each time if the taxpayer's controlled transaction meets all the requirements.

What we can do for you

We recommend checking the availability of additional exemptions from the TP documentation obligations. Get in touch with us. Our experts will check this tax avoidance opportunity for you.


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Dominika Tyczka-Szyda

Tax adviser (Poland)


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Daria Walkowiak-Dobner

Attorney at law (Poland)

Associate Partner

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