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Transfer pricing – what you need to do in Q1 2023


​by Daria Walkowiak-Dobner

27 January 2023

The first quarter of the new tax year brings a number of transfer pricing obligations. The most important ones to be met by taxpayers that are associated enterprises include filing the CBC-P notification and preparing the Master File.

Master File – who is obliged

Taxpayers carrying out controlled transactions with associated enterprises as defined in CIT and PIT Acts, if the consolidated revenues of the group in the previous year exceeded the threshold of 200 million zloty. To identify the company's obligations with respect to the preparation of the Master File, we recommend verifying the group's consolidated revenues for 2020.


The deadline for preparing the Master File has been extended by 3 months. So, for taxpayers whose tax year is the same as the calendar year, the deadline for preparing the Master File expires on 31 March 2023. 


The Master File is usually prepared at the head office level and contains information about the corporate group, including:

  • a description of the group;
  • a description of significant intangible assets;
  • a description of significant financial transactions;
  • financial and tax information.

The Master File should be in Polish or in English.

The fact that the Master File is prepared by a foreign entity does not exempt the Polish entity from the obligation to ensure that the File complies with the Polish laws. Therefore, we recommend a detailed review of your Master File. 

CBC reporting – who is obliged 

The CBC-P notification must be filed by members of a corporate group whose consolidated revenues following from the financial statements for the previous year exceed 750 million euro (3.25 billion zloty) and which, at the same time, do not file a separate CBC-R notification.

The CBC-P notification is to inform revenue authorities that the entity is:

  • a parent entity, designated entity or another entity filing the CBC-R or
  • a member of the group which is obliged to file the CBC-R and indicates the reporting entity and the country in which the CBC-R will be filed.


Entities obliged to file the CBC-P notification with the Head of the National Revenue Administration should do so within 3 months of the end of the group's reporting financial year. In most cases, the deadline for filing the CBC-P notification for 2022 will be 31 March 2023. To know if you are obliged to submit it, we recommend verifying the consolidated revenues of the group for 2021. 

The CBC-P notification must be filed in electronic form, via the e-Deklaracje system.

If you have questions about transfer pricing obligations, please contact us.


Contact Person Picture

Daria Walkowiak-Dobner

Attorney at law (Poland)

Associate Partner

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