The proceeding concerned the application of transfer pricing regulations. The favorable judgment of the Voivodship Administrative Court in Kraków, which reversed the contested decision of the tax authority, was lodged with the cassation appeal to the Supreme Administrative Court by by the tax authority.
The Supreme Administrative Court dismissed the cassation appeal of the body, sharing in full the position presented by the SPCG and the position accepted by the court of first instance, as regards errors committed by the tax authorities in the application of art. 11 of the Corporate Income Tax Act and implementing rules.
The proceeding was conducted by Agnieszka Soja – SPCG Partner.