Business Restructuring and the Arm’s Length Principle: From Legislative Amendments to Ministerial Guidelines

Abstract

Developments concerning the tax treatment of business restructurings at the OECD level seem to have influenced the Polish Ministry of Finance. The Ministry of Finance has amended transfer pricing regulations in order to tackle explicitly the problem of business restructurings, and later published its guidelines on the issue. This article summarizes these regulations and the guidelines, and notes certain problems connected with their content.