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The obligation to document transactions applies to taxpayers who make transactions with related entities (foreign or domestic), transactions with entities based in a country applying harmful tax competition, transactions with entities operating through a foreign establishment located in Poland. The subjective scope includes both CIT and PIT taxpayers. You can find more about it here >>

Entities are related if there are direct or indirect capital ( > 5% share in the capital of another entity) or personal (resulting from an employment relationship or family relationship) ties between them. A detailed description of the connections can be found here >>

The checking activities are undertaken by the tax authority ex officio. In this regard, the tax authority may undertake checking activities aimed at: checking timeliness: submitting declarations, payment of declared taxes, including those collected by payers and collectors, confirmation of the formal correctness of the documents listed in items 1, determination of the facts to the extent necessary to confirm compliance […]