A spin-off of an organised part of an enterprise, as well as a possible fee (the so-called exit fee) on this account, are tax-neutral and there is no risk of an overestimation of income on the basis of transfer pricing regulations.
Radosław Chudy of the transfer pricing team comments on the NSA's ruling of 1 April this year. The case concerned 'restructuring' analysed by the authorities and then the courts on the basis of older transfer pricing regulations. There were a number of issues: CPP, revaluation, exit fee, exemption, exemption, older and new transfer pricing rules. You can read the entire article in Monday's issue of Rzeczpospolita.