Ruling Regarding Default on Intercompany Loans: The Reason for an Income Adjustment

Journal
Rzymkowska, S.
Poland
International Transfer Pricing Journal 2012 (Volume 19), No. 4
FormatPDF
EUR
40
| USD
45 (VAT excl.)

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.