In a judgment of 7 July 2016 (case ref. no. II FSK 993/16), the Supreme Administrative Court confirmed its position presented before that a cash-pooling agreement and the relations between its participants are covered by the provisions of Article 9a.1 of the CIT Act, imposing on entities an obligation to prepare transfer pricing documentation.
In April we informed about the obligation to send uniform control files (UCF) starting as of 1 July 2016. In the answers to frequently asked questions regarding the structure of UCF available on the website of the Ministry of Finance as well as in a letter of 20 June 2016 (ref. no. PK4.8012.55.2016), the Minister of Finance clarified how the new regulations should be interpreted, also as regards the catalogue of entities subject to the new obligation.