Reporting obligations

In this category, we discuss transfer pricing reporting obligations in Poland, highlighting the importance of Polish regulations, EU and OECD guidelines. We point out the documentation obligation as a formal and legal requirement that requires the preparation of documentation describing transactions in accordance with local regulations.

We explain that starting in 2019, transfer pricing documentation is prepared on two levels: local and group. Local documentation includes a description of the related subject, its management structure, operations, and an analysis of functions, risks and assets. Group documentation, known as the “master file,” includes information on the group’s ownership structure, scope of operations and intangible assets. We emphasize the importance of proving the marketability of transfer pricing, which requires analysis of transactions between related and independent parties, taking into account financial and commercial data. We also review the transfer pricing information – a tool for analyzing applied prices in controlled transactions, introduced by the Ministry of Finance in 2019. We draw attention to the obligation to submit this information using the TPR-P/C form.

Finally, we take a closer look at the topic of transfer pricing adjustments, which can result from various factors, such as changes in economic conditions or deviations from pricing algorithms. We also discuss country-by-country reporting (CbC), which applies to domestic entities with consolidated revenues exceeding €750 million.

Documentation obligation

Tax documentation is an extremely important element in the context of transfer pricing. It is a formal and legal requirement that has been imposed on taxpayers by the regulations of a specific country. It consists in drawing up a document which describes, in accordance with the guidelines and tax regulations, a transaction or the sum of transactions subject to such obligation.Detailed guidelines […]

Local transfer pricing documentation

Elements of transfer price documentation In accordance with the provisions in force from 01/01/2019, transfer pricing documentation is prepared on two levels: Local transfer pricing documentation, Group transfer pricing documentation. Elements of local transfer pricing documentation (local file) Description of the related entity: description of the management structure and the organizational chart of the related entity description of the underlying […]