Poland's Ministry of Finance has announced the release of a final explanatory note (tax explanation) that provides guidance on a taxpayers' ability to make transfer pricing adjustments under an ex-ante arm's length price setting approach. In particular, the explanatory note addresses adjustments within the meaning of Article 11e of the Corporate Income Tax Act and corresponding provisions in the Personal Income Tax Act, which have been in force since 1 January 2019.
Under Article 11e, taxp…