The Administrative Court of Poznań, Poland issued a judgment on 11 January 2023 concerning the application of transfer pricing regulations to taxpayers under the distribution (lump sum) tax (the so-called Estonian CIT). The distribution tax regime, which is provided for in Chapter 6b of the Corporate Income Tax Act (CITA), essentially allows companies to be taxed only on profit distributions made.
The case concerned a taxpayer under the distribution tax regime, which claimed that the trans…