Poland's Ministry of Finance has issued an explanatory note with guidance on taxpayers' ability to make year-end, self-initiated, transfer pricing adjustments under a price-setting approach.
In 2019, Poland adopted the price-setting approach for transfer pricing, under which taxpayers are required to make a reasonable effort to comply with the arm's length principle at the time the taxpayers enter into controlled transactions. Under the price-setting approach, taxpayers cannot make a year-e…