There is good news: possible repeal of the obligation to prepare transfer pricing documentation for so-called indirect paradise transactions
The Ministry of Finance is in favour of repealing Articles 11o(1a) and 1b of the CIT Act. These provisions concern the documentation of so-called indirect paradise transactions.
The Finance Ministry’s decision is the result of public consultations in the tax legislation. Among the proposals for the necessary changes, tax experts suggested repealing these regulations and the MF takes this demand into account. Such a note was included in the report following the consultation.
– The repeal of these regulations will result in entrepreneurs not having to collect declarations about the real owner or paradise accounts, which in practice was very difficult and sometimes even impossible, assesses Cyprian Werykowski, tax advisor, director at Thedy & Partners.