The strength of the argumentation of the Law Firm’s requests for individual tax interpretations and complaints to administrative courts

The actions taken by attorney-at-lawr Paweł Sowisło, tax advisor Iwona Jacieczko, attorney-at-law Michał Górski and trainee attorney-at-law Jakub Wieczerzak drew the legislator’s attention to a legal loophole in the Corporate Income Tax Act.

Argumentation presented in requests for individual tax interpretations and complaints to administrative courts, which were prepared for our clients, led to the establishment of an additional exemption from application of transfer pricing regulations for transactions between a medical university within the meaning of Article 2.1.13 of the Healthcare Institutions Act of 15 April 2011 and a healthcare entity referred to in Article 6.6 of that Act.

The introduced provision of Article 11b clause 3 of the Corporate Income Tax Act narrows the group of entities which are obliged, among others, to have transfer pricing documentation or prepare complex information for the tax administration.