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Transfer pricing: obligations and deadlines for 2023

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​​​​​​​​​​​by Dominika Tyczka-Szyda

21 October​​ 2024


Deadlines for meeting transfer pricing​ obligations for 2023 are approaching. This applies to entities whose tax year is the same as calendar year.

The first deadline is already at the end of October, so be careful not to miss it – there are fiscal crime sanctions for non-compliance.

Local File


Taxpayers whose 2023 transactions with associated enterprises exceeded the statutory thresholds must prepare the Local File within 10 months of the end of the tax year, i.e. by the end of October 2024.

Transfer pricing report (TPR)


A transfer pricing report in the form of an electronic TPR form must be submitted by the 11th month of the end of the tax year, i.e. by 30 November 2024.

Master File


Master File must be prepared by taxpayers who belong to groups that achieved consolidated turnover of more than 200 million zloty in the previous tax year. They must do it by the end of the 12th month of the end of the tax year. So the Master File for 2023 must be compiled by 31 December 2024.

​obligatory document
deadline for 2023
​Local File
​31/10/2024
Transfer Pricing Report (TPR)
​30/11/2024
​Master File
​31/12/2024

Consequences


Failure to comply with transfer pricing documentation obligations is punishable by a fine imposed in the form of multiples of day-fine units. A day-fine unit must not be lower than one-thirtieth or be higher than the four-hundredfold of the minimum wage.

What is punishable?

  • failure to prepare the Local File, failure to attach the Master File or untrue information in the Local File – up to 720 day-fine units;
  • failure to file a TPR form or disclosure of untrue information or information which is inconsistent with the Local File – up to 720 day-fine units;
  • failure to prepare the Local File or a TPR form – up to 240 day-fine units.

Trust the experts


At Rödl & Partner we provide comprehensive advice on transfer pricing. We specialise in drafting, updating or reviewing mandatory transfer pricing documentation. If you have questions about deadlines related to transfer pricing or if you need our assistance in meeting the obligations, you are welcome to contact us.​

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Dominika Tyczka-Szyda

Tax adviser (Poland)

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