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Reporting obligations

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.

Polish legal regulations

Polish legal acts EU guidelines and reports OECD guidelines and reports Another

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Documentation obligation

Tax documentation is an extremely important element in the context of transfer pricing. It is a formal [...]

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Local transfer pricing documentation

Elements of transfer price documentation In accordance with the provisions in force from 01/01/2019, transfer pricing [...]

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Transfer pricing analysis

Proving that transfer pricing is arm’s length concerns a detailed analysis of transactions between related entities [...]

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Statement on the preparation of documentation

The obligation to submit a declaration on the preparation of local transfer pricing documentation applies to [...]

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TPR

Transfer pricing information Information on transfer prices is a tool created by the Ministry of Finance [...]

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Group transfer pricing documentation

Elements of group transfer pricing documentation (master file): Description of the capital group a description or [...]

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CT correction

Transfer pricing adjustments may result from: Changes in the economic environment in the year of the [...]

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CbC

Country-by-country reporting Domestic entities whose consolidated revenues, within the meaning of the accounting regulations, in the [...]

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