In particular, while reading through the reasoning presented by the Polish tax authorities in tax rulings issued in individual cases, we identify that TP
adjustments:
- Remain outside the scope of VAT if they relate to the entire profitability result achieved in a given period and are not linked to specific supplies between related entities (i.e., do not refer to specific invoices, individual items of these invoices or to prices originally applied)
- Should be included in VAT settlements if they relate to specific supplies performed between related entities in a given period (i.e., there is a link between TP adjustments and specific invoices or prices of goods or services)
Source: EY (page 69)
