Reporting obligations
In this category we discuss the reporting obligations connected with transfer pricing in Poland, stressing the importance of Polish regulations and of EU and OECD guidelines. We draw attention to the documentation obligation as a formal legal requirement that calls for documentation describing transactions in line with local regulations.
We explain that since 2019 transfer pricing documentation has been prepared at two levels, local and group. The local file covers a description of the related party, its management structure and activity, and an analysis of functions, risks and assets. The group documentation, known as the master file, contains information about the ownership structure of the capital group, the scope of its activity and its intangible assets. We stress the importance of demonstrating that transfer prices are at arm's length, which calls for an analysis of transactions between related and independent parties taking financial and commercial data into account. We also discuss the transfer pricing return, a tool for analysing the prices applied in controlled transactions introduced by the Ministry of Finance in 2019. We draw attention to the obligation to file this return on form TPR-P/C.
Finally, we look at transfer pricing adjustments, which may follow 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 revenue exceeding EUR 750 million.