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The deadline for preparing transfer pricing documentation is drawing nearer


​by Paulina Janka

25 August 2023

The deadlines for meeting transfer pricing obligations for 2022 are approaching quickly. As of now, the Ministry of Finance has not extended the deadlines like it did in previous years. 

Therefore, applicable are the deadlines prescribed explicitly in income tax laws. In practice, this means that taxpayers have one month less time to file the TPR form.

Transfer pricing reporting deadline

Taxpayers whose tax year coincides with the calendar year and whose transactions with associated enterprises exceeded the statutory value thresholds in 2022 are obliged to prepare transfer pricing documentation of those transactions by the end of October 2023.

Currently, the deadline for meeting the reporting obligations, i.e. for filing the TPR form, expires at the end of the eleventh month after the tax year. So in the case of taxpayers whose tax year is the same as the calendar year, the deadline for filing the TPR form for 2022 will expire on 30 November 2023. 

Changes to transfer pricing reporting

Please note the key changes to transfer pricing reporting for 2022.

1. Change of TPR addressee

TPR forms for 2022 will no longer be filed with the Head of the National Revenue Administration, but with the head of the competent revenue office. 

2. Statement and TPR are one and the same document

Previously, the statement was a separate document. Now, it is an integral part of the TPR form, so filing the TPR means filing the statement as well. 

3. Change of the TPR signing rules

There are now fewer people who may sign the TPR. The 2022 transfer pricing report must be signed by the entity’s manager, a designated board member, or an attorney. If the document is to be signed by an attorney, this must be a professional attorney, that is, an attorney at law (adwokat, radca prawny), a tax adviser or a statutory auditor. In practice, therefore, the TPR will have to be filed by a board member; accountants will no longer be allowed to sign and submit the TPR.

4. New TPR template

The TPR form must be submitted electronically, so in practice only one person can sign and send it. It is therefore necessary to get ready beforehand, as that person must be authorised to sign the form by means of a power of attorney on the UPL-1 form and must have an electronic signature. 

New TPR form

As announced, the new TPR form (version 5), which has to be used to report transactions made in 2022, will not be published until the third quarter of 2023. Before the publication of the new TPR-C and TPR-P forms, the valid TPR template for 2022 is the template which does not include a separate part containing the statement on preparation of the local file (version 4). Until the new template is published, the Ministry of Finance allows filing the report on the current version 4 template. To submit the statement using version 4 of the TPR template, taxpayers may write the statement in the template’s Section F “Additional Information”. They may do so only until the new electronic template of the TPR-C and TPR-P forms (version 5) is published.

You are welcome to contact us. We will gladly assist you in preparing your TPR form and provide advice on all aspects of transfer pricing.


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Paulina Janka

Tax adviser (Poland)

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