Our client is a Polish company, which runs activity in Poland and also in other countries. Company has a permanent establishment in:
- Switzerland, Germany, Austria, Luxembourg (permanent establishments which are also formal branches);
- Belgium, Sweden (permanent establishment which are not a formal branch).
From couple years company divide administrative SSC cost on all of the branches using income key. Divided costs does not include any mark-up. Now company is wondering if it is reasonable to start adding mark-up on costs. From the Polish perspective we think that it could be risky to start adding mark-up from now, while do not correct previous years. Company has no justification for making change only for future, not adjusting past.
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Dear Sir or Madam
We invite you to fill out a short questionnaire, which will allow us to set the most convenient time for an online meeting. The expected duration of the meeting - 1 hour.
There are 2 questions in this survey.