Polish Supreme Administrative Court clarifies whether companies under Estonian CIT must comply with transfer pricing regulations.
Case Background
The case concerned a company that chose to be taxed under the flat tax on corporate income. It therefore applies the provisions of Chapter 6b of the CIT Act.
The company conducts transactions with related parties, so it had doubts whether, as an entity accounting under Estonian CIT rules, it must apply the transfer pricing provisions.
Transfer Pricing Provisions in Question
The specific articles in question are Articles 11k-11t and Article 11e of the CIT Act, which govern transfer pricing documentation requirements.
Dispute Over Estonian CIT Obligations
The ruling addresses a long-standing dispute about the intersection of Estonia’s special CIT regime and Poland’s transfer pricing regulations.
