Due care procedures for transactions with tax havens



Taxpayers who transact with business partners must prepare a Local File if:

  • the transaction value exceeds 500 thousand zloty in a single tax year;
  • the beneficial owner has a domicile, registered office or management board in a territory applying harmful tax competition.

Importantly, the TP documentation is required not only in respect of transactions with associated enterprises but also with independent entities.

Due care should be exercised when establishing these circumstances.


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  • sufficiently diligent examination of the transactions;
  • list of transactions to be documented.

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