OrbitaxPolish Supreme Administrative Court Confirms Companies Under Distribution Tax Regime are Subject to Transfer Pricing Documentation Requirements
|Approved Changes|Poland
Poland's Supreme Administrative Court issued a judgment on 17 February 2026 concerning the application of transfer pricing regulations to taxpayers under the distribution (lump sum) tax (the so-called Estonian CIT). The distribution tax regime, which is provided for in Chapter 6b of the Corporate Income Tax Act (CITA), essentially allows companies to be taxed only on profit distributions made.…