Poland - Failure to Demand Payment of Interest and Its Transfer Pricing Implications
- K. Lasiński-Sulecki; W. Morawski
- International Transfer Pricing Journal, 2015 (Volume 22), No 4
- 9 July 2015
Polish courts have recently held that transfer pricing provisions may apply in the case where the arm’s length contractual stipulations were executed in a way departing from the arm’s length standard. They also claimed that hypothetical transactions that would have taken place if transactions between associated enterprises had been at arm’s length, should have been considered in evaluating whether transfer pricing provisions were applicable.