Author Archive:
Magdalena Marciniak
How can you effectively manage and care for your energy?
Read more: How can you effectively manage and care for your energy?With the demands of modern work, we often find ourselves juggling tasks and facing increasing expectations for productivity. With the demands of modern work, we often find ourselves juggling tasks and facing increasing expectations for productivity. This can lead to overwork, changing environments, and pressure for results, which can ultimately result in burnout. By implementing…
Transfer pricing across borders: our international solutions
Read more: Transfer pricing across borders: our international solutionsTransfer pricing is (primarily) an international issue. Why? Because business is international. These two aspects are intertwined and complete each other. Increasingly, organizations recognize the value of strategic transfer pricing management. Well-structured transfer prices not only supports robust business development, but also promotes it. However, it is crucial to remember that transfer pricing are not…
6 ways to effective communication
Read more: 6 ways to effective communicationEffective business communication is crucial for customer satisfaction and the professional success of employees, thereby impacting the entire team’s development. It forms the foundation of company growth. Managing a team of over 50 people presents significant challenges due to its size and diversity. Therefore, effective communication is crucial for promoting collaboration, enhancing employee engagement, and…
Diversity in the Team
Read more: Diversity in the TeamAdam Grant: The goal of a great discussion isn’t to land on the same page. It’s to explore different views. Nods and smiles stroke your ego and close your mind. Thoughtful questions stoke your curiosity and stretch your thinking. Consensus makes you comfortable. Dissent makes you smarter. Many modern management textbooks emphasise the importance of…
Service transactions – a new focus for Polish tax authorities?
Read more: Service transactions – a new focus for Polish tax authorities?It is a truth commonly acknowledged that related-party settlements have been scrutinized by tax authorities for several years. In 2022, more than 500 transfer pricing controls in Poland were taking place: 370 were completed and 242 were pending. In 2022 alone, the amount of additionally estimated income exceeded PLN 1 billion (almost PLN 220m more…
Not only the median is arm’s length – a Polish case study
Read more: Not only the median is arm’s length – a Polish case studyThe Polish Administrative Court found that tax authorities wrongly questioned the results of the taxpayer’s benchmarking analysis. Read more to get the Polish perspective. Facts A Polish company from a group of related entities provided cigarette production services based on materials entrusted to a UK-based related entity, which was the main source of the company’s…
Meet The Members Europe – Transfer pricing: the key issues in Poland
Read more: Meet The Members Europe – Transfer pricing: the key issues in PolandKey issues Regulations on transferring income between related parties have existed for a long time in Polish tax law. However, transfer pricing matters have gained importance in Poland relatively recently. Even though Polish transfer pricing regulations are aligned with the OECD Guidelines, they are at the same time highly detailed. Simply relying on the OECD…
OECD’s document on MAP and APA procedures
Read more: OECD’s document on MAP and APA proceduresOn 1 February, OECD released a Manual on the Handling of Multilateral Mutual Agreement Procedures and Advance Pricing Arrangements (MoMA). As a reminder, in 2022, OECD Manual on Bilateral APAs was published. MAP and APA are procedures designed to ensure the security of the taxpayer in the field of controlled transactions. They allow the acceptance…