Transfer pricing Poland: Changes to reporting deadlines

Poland has changed its transfer pricing reporting deadlines from the beginning of 2023. Businesses now have more time to prepare local transfer pricing documentation. The Ecovis experts know the details and the other changes.

The changes are part of an amendment to the Corporate Income Tax Act. Currently, local transfer pricing documentation must be prepared by the end of the tenth month after the end of the tax year (previously it was the end of the ninth month).

Deadline for submitting information on transfer prices (TPR form)

The amendment also changed the deadline for preparing and submitting information on transfer pricing (TPR form). Currently, the TPR form must be prepared by the end of the eleventh month after the end of the tax year (previously it was the end of the ninth month).

The recipient of the information has also changed. Currently, it must be sent to the head of the tax office responsible for the taxpayer (previously, it was the Head of The National Tax Administration).

In addition, it should be noted that the previously submitted separate statement on the preparation of local transfer pricing documentation has now become part of the TPR form.

However, as in previous years, the above-mentioned deadlines may be extended on the basis of the provisions on special solutions related to the prevention, counteraction and combating of COVID-19.

We will determine whether transactions are subject to TP reporting and prepare all the documentation for you.

Hubert Kaczyński, Tax Advisor, ECOVIS Poland Audit, Tax & Accounting, Warsaw, Poland

How to provide information on transfer prices (TPR form)

The information on transfer pricing must be submitted to the relevant tax office on the basis of the electronic document template published in the Public Information Bulletin (Biuletyn Informacji Publicznej) on the website of the office providing services to the minister responsible for public finance. In practice, TPR forms are submitted via the electronic tax return submission system (e-Deklaracje).

Transactions with companies resident in tax havens

The scope of transactions with companies based in a tax haven, i.e., with harmful tax competition (haven transactions), is also changing.

In the case of so-called intermediate haven transactions, i.e., transactions in which the beneficial owner of the receivable is a resident of a tax haven, the obligation to prepare local transfer pricing documentation has been eliminated.

However, in the case of direct haven transactions, i.e., transactions with an entity based in a tax haven, the documentation threshold for the obligation to prepare local transfer pricing documentation has been increased.

The threshold is now:

1. PLN (Polish złoty) 2,500,000 for financial transactions
2. PLN 500,000 for other transactions

For further information please contact:

Hubert Kaczyński, Tax Advisor, ECOVIS Poland Audit, Tax & Accounting, Warsaw, Poland
Email: hubert.kaczynski@ecovis.pl