Shaping the Transfer Pricing Practice in Delineation of Transaction – Review of Judicial Decisions in Poland

Journal
Poland
International Transfer Pricing Journal 2023 (Volume 30), No. 6
This article addresses the development of domestic tax practice in Poland on issues related to the delineation of transaction in the context of transfer pricing. An overview of the most relevant court jurisprudence is presented, highlighting the changing positions on the part of both tax authorities and administrative courts over the last decade.