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.
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.