Transfer pricing in the Polish Investment Zone

Abstract

The subject of this paper was the application of transfer pricing rules by entities

operating on the basis of the decision on support, in the areas indicated in that decision

within the framework of the investment support programme, which is the Polish Investment

Zone. The aim of this article was to clarify the issues of transfer pricing in the context of the

PIZ, which is the direct successor to the SEZ as an investment support instrument.

The analysis conducted has shown that the generally applicable legal regulations indicate that

the rules resulting from the transfer pricing regulations should be applied to settlements

between entities within and outside the area indicated in the decision on support. Similarly

as in the SEZ, flows between entities should take place according to the arm’s length

principle. On the other hand, entrepreneurs having an entity in the area covered by the

decision on support and outside this area are not obliged to prepare statutory transfer pricing

documentation.