Elements of group transfer pricing documentation (master file):

Description of the capital group

  1. a description or a diagram of the ownership structure of the capital group along with the name
    and seat or place of management of its entities
  2. description of the subject and scope of activities carried out by the capital group

Description of significant intangible assets of the capital group

  1. general description of the capital group’s strategy in the field of creation, development, ownership and use of intangible assets along with information on the location of significant research and development centers and the locations of centers managing research and development functions
  2. a list of intangible assets or groups thereof significant from the point of view of transfer prices with an indication of entities with legal titles to these values
  3. a list of significant agreements or agreements concluded between related entities of the capital group regarding intangible assets, including agreements on cost sharing, agreements for conducting research and development works and license agreements
  4. description of the capital group’s transfer pricing policy in the field of research and development activities as well as intangible assets
  5. a general description of significant changes in the control and ownership of intangible assets
    and the use of these values, together with an indication of the entities involved, their registered office or place of management and the remuneration or compensation paid for these changes

Description of significant financial transactions of the capital group

  1. a general description of the methods of financing the activities of the capital group, including information
    on significant financing agreements concluded with unrelated entities
  2. indication of entities performing functions in the field of central financing within the capital group as well as their seat and place of actual management
  3. a general description of the transfer pricing policy in the field of financing between related entities

Financial and tax information of the capital group

  1. annual consolidated report of the capital group
  2. a list and a concise description of unilateral advance pricing agreements or other tax interpretations between countries concluded by the related entities of the capital group.

The detailed scope of elements of group transfer pricing documentation is defined in the Regulation of the Minister of Finance of December 21, 2018 on transfer pricing documentation in the field of corporate income tax / personal income tax.

Group documentation (so-called master file)

In the case of a taxpayer (or a company that is not a legal person, in which the taxpayer obtains income from participation), if the income of that taxpayer or that company or costs, within the meaning of the accounting regulations, exceeded in the case of a taxpayer in the year preceding the tax year, and in the case of a non-person company in the previous financial year within the meaning of the accounting regulations, the equivalent of EUR 20 million, the tax documentation prepared by him should also  contain information about the group of related entities , which includes the taxpayer (apart from the so-called local documentation).

This information includes in particular:

  1. indication of the related entity that prepared information about the group of related entities, along with the date of submitting the tax return;
  2. organizational structure of a group of related entities;
  3. description of the principles of determining transaction prices (transaction price policy) applied by a group of related entities;
  4. description of the subject and scope of activities carried out by a group of related entities;
  5. a description of material intangible assets owned, created, developed and used in the activities of a group of related entities;
  6. description of the financial situation of the entities forming the group together with the consolidated statements of related entities forming the group of related entities;
  7. description of income tax agreements concluded by entities forming a group of related entities with tax administrations of countries other than the Republic of Poland, including unilateral advance pricing agreements.

Pursuant to the Regulation of the Minister of Finance of March 14, 2018 on the extension of the deadlines for the performance of certain obligations in the field of tax documentation, the deadline for the preparation of tax documentation, submission to the tax office of a declaration of preparation of tax documentation, and attachment to the tax return is extended until the end of the ninth month after the end of the tax year. tax for the tax year of the simplified statement

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