The corporate tax rate is 19%. A reduced 15% tax rate may apply to small companies and start-ups (in case of start-ups – only in the first year) if certain criteria are satisfied. A small company is an entity with sales revenues (inclusive of VAT on goods and services) that did not exceed the PLN equivalent of EUR 1.2M in the preceding year.
Transfer pricing is regulated by Article 11 of the Corporate Income Tax Law and Article 25 of the Personal Income Tax Law. Regulations that apply to cross-border as well as domestic transactions. These regulations are based on the OECD Guidelines. The thresholds for the documentation requirements are relatively low, and the requirements apply to a wide range of transactions.
Transfer Pricing Case Law