Following a public consultation held in May, Poland has revised its proposed transfer pricing (TP) documentation rules. Two key changes from the previous draft include:
- The shareholding threshold for determining if parties are related would be increased from 5% to 25%, instead of 20% as previously proposed; and
- The entry into force date is delayed one year, from 1 January 2016 to 1 January 2017
In addition, a new transaction value based threshold is included in the draft rules. The EUR 2 m…