Changes to the Minister of Finance Decree on transfer pricing – part8: Low value-adding services


The change of 17 June 2013 to the transfer pricing Decree in Poland introduced the notion of „low value-adding services”. In the Decree, they are defined as:


·         services that have a routine nature,


·         support the core activity of the service recipient,


·         are generally or easily available,


·         do not contribute to adding great value neither to the provider of the services nor to the recipient of the services.


Costs related to the provision of these services cover direct and indirect costs, excluding shareholder costs – that is costs that bring benefit only to the shareholder. A catalogue of exemplary shareholder costs is attached to the Decree.


In the Decree, there is also a catalogue of examples of low value-adding services; it includes the following services:


A.      Information technology services,


B.      Human resource services,


C.      Marketing services,


D.      Legal services,


E.       Accounting and admin services,


F.       Technical services, including the transfer of technical knowledge,


G.     Quality control,


H.      Other, for instance, services on strategy and development of a companies.


The level of Mark-up on these services and the special documentation for these services (so called description) we shall summarize in the next issue of our Newsletter, next week.


Prepared by Tax Advisory Company TCA Advisers Sp.z o.o. , Konstancin-Jeziorna, Warsaw


NOTE: This material is prepared for information purposes only – care was taken to make it as simple and clear as possible, so it is not complete nor precise enough to the basis for any action in practice – therefore, in case you need to resolve your particular situation, please seek professional tax advice. 


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