Poland - Ruling Regarding Default on Intercompany Loans: The Reason for an Income Adjustment
- S. Rzymkowska
- International Transfer Pricing Journal, 2012 (Volume 19), No 4
- 26 June 2012
The author considers a ruling by the Lower Administrative Court in Warsaw regarding a disputed tax assessment in connection with intercompany loans which had not been settled in accordance with the relevant internal loan agreements. The case is still subject to an appeal procedure, so the conclusions of the case may change due to Supreme Administrative Court’s judgment.