Poland: Upcoming Transfer Pricing Reporting TPR Filing Deadline

Contacts

bartlomiej sikora module
Bartlomiej Sikora

Senior Counsel
Poland

As Senior Counsel and Head of our Tax team in Warsaw, I am an expert in all tax matters and advise on issues regarding corporate transactions, energy, M&A and real estate.

mateusz bednarski module
Mateusz Bednarski

Senior Associate
Poland

I am a senior associate in our Tax team in Warsaw. I support clients on a range of tax issues.

Related parties preparing local transfer pricing documentation or carrying out controlled transactions that are exempt from such documentation (e.g., domestic transactions or safe-harbour arrangements) are required to file TPR information by the end of the eleventh month following the end of the tax year. 

Where the tax year corresponds to the calendar year, the filing deadline for TPR covering 2024 is 1 December 2025.

TPR information must include, i.a.:

  • General financial information;
  • Parameters of controlled transactions;
  • Transfer pricing verification methods; and
  • A statement confirming compliance with the arm’s-length principle.

Filing is conducted exclusively electronically. The signature may only be provided by the head of the organisation or by an authorized professional representative (tax adviser, legal counsel, attorney, or certified auditor). Failure to fulfil this obligation may expose members of management to criminal fiscal liability.

TPR is one of the tax administration’s key tools for assessing the risk of income understatement — errors, incorrect data presentation, or delays can increase the likelihood of a tax audit.

Our offer

We provide:

  • Analysis of transactions subject to reporting;
  • Preparation of TPR information;
  • Support with the signing and submission process; and
  • Advisory services on appropriate transfer pricing documentation.

Please contact us — we will guide you through the entire process professionally and efficiently.

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