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Transfer pricing


Polish legislation

Transfer pricing is one of the most significant aspects of international tax law. The regulations on taxation of associated enterprises are present in the Polish tax legislation, which has been amended for the last 10 years. The amendments have resulted in additional financial and administrative burdens for taxpayers.

Transfer pricing vs tax authorities

The amendments have brought more frequent tax inspections of transactions among associated enterprises. It is very important to know the transfer pricing rules, including the transfer pricing documentation requirements. To help you deal with the challenges of proper application of the regulations we invite you to use the knowledge of Rödl & Partner's tax law experts, who ensure effective transfer pricing advice.


A new TPR form – information for taxpayers with non-standard tax year »

The reporting deadline for taxpayers whose tax year matches the calendar year, i.e. the deadline to prepare and file the transfer pricing report (TPR form) for 2022, expired on 31 January 2024.


Transfer pricing – not all transactions have to be documented »

Businesses affected by transfer pricing laws should check their transactions with associated enterprises carefully. This is because it may turn out that some of their controlled transactions need not be documented.


Interest rates on intra-group loans in the context of the safe harbour mechanism »

The Minister of Finance's announcement of 27 December 2023 specifies the type of base interest rate and the amount of the margin that allow the use of the safe harbour regime.


TPR form filing deadline extended »

A regulation extending the deadline for filing the transfer pricing report has been published in the Journal of Laws.


Transfer pricing adjustment »

As the end of the year is nearing, the issue of transfer pricing adjustment among associated enterprises is worth exploring.


Transfer pricing: TPR filing deadline extended »

The Ministry of Finance (MF) has published a draft regulation extending the deadline for filing the transfer pricing report (TPR).


Transfer pricing: deadlines applicable to 2022 »

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.


The deadline for preparing transfer pricing documentation is drawing nearer »

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.


Transfer pricing reporting obligations – what’s new »

2023 sees another round of changes in transfer pricing legislation.


Resale price method – explanatory notes of the Ministry of Finance »

In March 2023, the Ministry of Finance published its explanatory notes on the application of one of the five basic transfer pricing verification methods – the resale price method.


Transfer pricing report (TPR) – a new ratio from 2022 »

Most taxpayers satisfied their 2021 transfer pricing obligations by the end of December 2022.


Changes in transfer pricing – obligations in 2023 »

Tax legislation, including on transfer pricing, changed frequently in 2022.


Transfer pricing – what you need to do in Q1 2023 »

The first quarter of the new tax year brings a number of transfer pricing obligations.


Year-end adjustment of transfer prices »

According to Polish CIT law, there are limitations for the possibility of including transfer pricing (TP) adjustments into tax-deductible expenses.


Transfer pricing reporting – FAQs »

The Ministry of Finance published another edition of "Transfer pricing reporting – FAQs" at the end of October 2022.


Polish Deal 3.0: Transfer prices and other changes in CIT »

On 21 October 2022, the Polish President signed the bill amending the Corporate Income Tax Act (the CIT Act) and some other acts.


Polish Deal: no more documentation obligation for indirect transactions with tax havens »

The bill amending the CIT Act, which is to continue work on the next version of the Polish Deal, is now in the lower chamber of the Polish parliament (Sejm).


Loan in the transfer pricing context: transaction threshold = value of principal used »

If a company grants a loan to its associated enterprise, the transaction should be recognised at the actually used amount of the principal – this is the gist of the advance tax ruling issued by the Head of the National Revenue Information Service (NRIS) on 12 July 2022.


Business partner screening in transactions with tax havens – how to avoid problems? »

Although more than one and a half year has passed since the enactment of laws on indirect transactions with tax havens, the application of the laws is still unclear to many taxpayers.


Deadlines for fulfilling TP obligations extended »

The Polish President signed on 10 June 2022 the act amending certain acts to automate processing of certain matters in the National Revenue Administration.


Transactional net margin method – tax explanatory notes of the Ministry of Finance »

The Ministry of Finance Transfer Pricing and Valuation Department published at the beginning of December 2021 the final version of transfer pricing explanatory notes no. 4 concerning the transactional net margin method.


Deadlines for preparing transfer pricing (TP) documentation are drawing near »

Taxpayers obliged to prepare the Local File and whose financial year corresponds to the calendar year have time until 31 December 2021 to file the transfer pricing report (TPR form) and the statement on preparing TP documentation.


Polish Deal in transfer pricing practice »

For several months now, business representatives and tax advisers have kept a watchful eye over machinations of the Polish lawmakers.


Transfer pricing adjustment – the final version of the explanatory notes of the Ministry of Finance »

Amended Corporate Income Tax Act (CIT Act) entered into force on 1 January 2019 bringing a number of changes to transfer pricing laws.


Consultations of the Ministry of Finance concerning due care procedure for transfer pricing »

Rödl & Partner experts took part in consultations conducted by the Ministry of Finance (MF) concerning new transfer pricing obligations.


Review of 2019 transfer pricing documentation of Polish entities – why it’s worth it »

Further modifications to Polish transfer pricing regulations were introduced on 1 January 2019. The regulations were adjusted to the OECD guidelines.


Voluntary cancellation of shares with no compensation – transfer pricing laws do not apply »

Chapter 1a of the Corporate Income Tax Act of 15 February 1992 provisions on transfer pricing, does not apply to the voluntary cancellation of shares in a limited liability company with no compensation.


Transfer pricing legislative changes 2021 »

It is no longer surprising that taxpayers can expect changes to transfer pricing laws at the start of every year. This year is no different – another set of amendments entered into force on 1 January.


Why review your 2020 transfer pricing documentation? »

The COVID-19 pandemic has affected the financial position of many enterprises. This has often necessitated an adjustment to the accounts of intra-group transactions.


Why review your transfer pricing documentation for 2019? »

Further modifications to transfer pricing regulations were introduced on 1 January 2019.

GLOBAL APPROACH – Digital Tax Transformation

Globalisation in tandem with digitalisation is changing the contemporary business world. For many companies this means incorporating digital technologies into their overall business processes.


Deadlines for fulfilling TP obligations extended »

The Public Finance Committee passed a parliamentary amendment to the draft act amending the Excise Duty Act and some other acts at its yesterday’s session.


Transfer pricing adjustment – do the new obligations apply to your company? »

Please be reminded that the Corporate Income Tax Act contains detailed rules for the admissibility of transfer pricing adjustments (TP adjustment) from 1 January 2019.


Transfer pricing in the context of pandemic – OECD Guidance »

The OECD published Guidance on the transfer pricing implications of the pandemic in December 2020.


TPR Return – Clarifications by the Ministry of Finance »

Taxpayers with a tax year corresponding to the calendar year should file their first transfer pricing information return (i.e. TPR return) by the end of December 2020.


Planned changes to transfer pricing »

The Polish Sejm adopted the bill amending the Personal Income Tax Act, the Corporate Income Tax Act, the Act on Flat Income Tax on Certain Income earned by Natural Persons and Some Other Acts.


Transfer pricing documentation – deadlines getting closer »

Most of the entities obliged to prepare the Local File had to submit the information on transfer pricing (TPR form) and the statement on transfer pricing documentation by 31 December 2020.


MDR – repeated reporting of cross-border arrangements »

As the regulations on reportable tax arrangements were amended again, effective 1 July 2020, the previously assigned reportable cross-border arrangement numbers (NSP) had been invalidated.


Transfer prices under investigation no matter the pandemic »

Despite the worldwide pandemic tax authorities are not standing still and continue their inspections and launch new ones.


Cooperative compliance agreement instead of APA? »

The Polish Tax Act was amended with effect from 1 July 2020 to include provisions enabling taxpayers to sign a cooperative compliance agreement.


Adjustment of prices of specific goods and services outside the scope of transfer pricing adjustment »

Adjustments made during the tax year to prices of goods involved in transactions between associated enterprises are not subject to the principles of Article 11e of the CIT Act.


Tax loss and the option to exempt taxpayers from the obligation to prepare transfer pricing documentation »

The Head of the National Revenue Information Service confirmed that whenever the criterion of no tax loss in a tax year is tested, this refers to a loss from a specific source of income which includes taxable transactions with a Polish associated enterprise.


Transfer pricing analysis as more and more important element of transfer pricing documentation »

Pursuant to the regulations in force since 2019, transfer pricing analysis is an obligatory element of each transfer pricing documentation, except for transactions made under the safe harbour regime.


Transfer Pricing Forum on restructuring among associated enterprises »

The Transfer Pricing Forum (TPF) published on 3 March 2020 its recommendations on the interpretation and application of provisions on restructuring among associated enterprises.


OECD’s Transfer Pricing Guidance on Financial Transactions »

The OECD released Transfer Pricing Guidance on Financial Transactions on 11 February 2020. The report includes many guidelines which may be helpful.


Transfer pricing adjustment non-VATable »

The Head of the National Tax Information Service confirmed in the advance tax ruling that neither downward, nor upward adjustment was subject to VAT.


APA: costs may be deducted only until the end of the year »

The Polish President signed the Act on Resolving Double-Taxation Disputes and Concluding Advanced Pricing Agreements (DMR Act) on 5 November 2019.


Recharges and the obligation to prepare a benchmark study »

The Polish Corporate Income Tax Act (“CIT Act”) and the Polish Personal Income Tax Act (“PIT Act”) were amended on 1 January 2019.


New rules of transfer pricing adjustments »

Transactions with associated enterprises must be made at arm’s length, that is, on terms which independent enterprises would agree.


New powers for tax authorities – recharacterisation and non-recognition of transactions »

One of the key changes introduced to the transfer pricing regulations with effect from 1 January 2019 is that tax authorities will now have new tools to challenge payments between associated enterprises.


Modern transfer pricing reporting procedure (TP-R) »

The obligation to report transfer prices in electronic form (TP-R) came into force on 1 January 2019.


New rules of country-by-country (CbC) reporting »

The President of Poland signed an Act on exchange of tax information with other countries on 20 March 2017.


The deadline for filing CBC-P for 2018 is approaching »

We are writing to remind you that if your reporting financial year corresponds to the calendar year you have to notify the authorities whether you are obliged to prepare a CbC report for 2018.


Another revolution in transfer pricing starting from 1 January 2019 »

On 14 November 2018, the Polish President signed the statute amending the Personal Income Tax Act (the PIT Act), the Corporate Income Tax Act (the CIT Act), the Tax Act and some other acts.


The MAP or how to avoid double taxation? »

Transfer pricing is one of the most frequently inspected areas in enterprises that belong to international groups.


Transfer pricing 2019 – new documentation obligation provisions »

The recent amendments to the transfer pricing laws have prompted numerous interpretation doubts and difficulties in fulfilling documentation obligations.


How to interpret the group of associated enterprises for Master File purposes? »

Taxpayers whose revenues or costs as per the Polish accounting laws exceeded the equivalent of EUR 20 million in the year preceding the tax year must prepare the so-called Master File.


New templates of PIT-TP and CIT-TP simplified information »

The Ministry of Finance has recently published two regulations on its website, which introduce new templates of PIT-TP and CIT-TP simplified information returns.


Complete transfer pricing documentation as a condition for its acceptance by tax authorities »

Taxpayers often wonder what information to include in the transfer pricing documentation so that tax authorities accept it as reliable evidence.


Tax-consolidated groups – transfer pricing »

Tax-consolidated groups (TCG) were often used as an aggressive tax optimisation tool. The lawmakers have recently taken measures aimed at limiting such optimisation mechanisms.


Transfer pricing – obligation to update TP documentation »

On 3 April 2018, the Minister of Finance published general advance tax ruling no. DCT.8201.6.2018 dated 28 March 2018 concerning the obligation to update transfer pricing documentation.


A company and its foreign permanent establishment are associated enterprises »

The obligation of companies operating through their foreign permanent establishments to prepare transfer pricing documentation follows directly from the relevant provisions of the CIT Act.


Tax returns vs longer deadlines for meeting transfer pricing documentation obligations »

In connection with the extension of deadlines for meeting transfer pricing (TP) documentation obligations, on 16 March 2018 the Ministry of Finance published practical explanations.


Transfer pricing documentation for all transactions – not only for those over the threshold »

If your sales exceed EUR 100,000, you must prepare a transfer pricing documentation of all transactions concluded in a tax year with the given associated enterprise.


Transfer prices and low value-added services – legislative changes »

Definition of low-value added services was added to the transfer pricing provisions on 18 July 2013. This amendment is important for Polish taxpayers operating as part of corporate groups.


Extending deadlines for compliance with transfer pricing obligations »

The Ministry of Finance has taken measures to make the deadlines for meeting transfer pricing (TP) documentation obligations more realistic and to simplify regulations in this scope.


Transfer pricing – controversial general tax ruling »

The Ministry of Finance has issued a general tax ruling on transfer pricing. It touches upon the most disputable laws regulating this issue.


New obligation to file CIT/TP report in Poland »

We would like to remind you of the new obligation to file a summary report (CIT/TP) for the tax year commencing after 31 December 2016, which should be attached to the annual tax return.


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Dominika Tyczka-Szyda

Tax adviser (Poland)


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