TPR

Transfer pricing information

Information on transfer prices is a tool created by the Ministry of Finance to analyze prices applied by taxpayers in controlled transactions. The obligation to submit information on transfer pricing using the TPR-P / C form was introduced on January 1, 2019. In the previous legal state, simplified CIT-TP and PIT-TP forms were in force.

The TPR information must be submitted by 9 months after the end of the tax year . It is submitted only in electronic form to the Head of the National Revenue Administration.

Both related entities obliged to prepare tax documentation and entities that benefit from the exemption from the obligation to prepare the documentation are required to prepare this information.

Transfer pricing information (TPR) is a collection of information on transactions concluded between related entities and between taxpayers and entities residing, having their registered office or management in the territory or in a country applying harmful tax competition (so-called “tax havens”).

The TPR Information should show:

• controlled transactions subject to the obligation to prepare local transfer pricing documentation, and
• Controlled transactions exempt from the obligation to prepare local transfer pricing documentation (so-called “domestic transactions”), and
• receivables paid to entities based in countries and territories applying harmful tax competition, provided that the value of these receivables and contracts exceeds the thresholds of PLN 100,000.00,
• receivables paid, the actual owner of which has its registered office or management board in a state and territory applying harmful tax competition, provided that the value of these receivables exceeds the threshold of PLN 500,000.00.

Transfer pricing information items include:

1. the purpose of submitting the information and the period for which it is submitted
2. identification data of the entity submitting the information and the entity for which the information is submitted
3. general financial information of the entity for which the information is submitted
4. information on related entities and controlled transactions
5. information on transfer methods and pricing
6. additional information or clarification.