1 December 2021 the Polish Ministry of Finance issued Tax clarifications on transfer pricing No. 4: Transactional Net Margin Method (TNMM)
Clarification on application of the TNMM is provided in these areas:
A. Principles of TNMM use
A.1. Scope of application of the method
A.2. Tested party
A.3. Determination of net profit margin
A.4. Definition of the base
A.5. Choice of profitability indicator
A.6. Profitability comparison
B. Criteria for comparability of transactions and entities
C. Difficulties in applying TNMM
D. Comparison with other methods
E. Practical application of TNMM
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