Transfer pricing has for many years been one of the main areas of focus for tax authorities. In practice, this means that transactions between related parties are subject to heightened scrutiny, and the associated documentation obligations are among those most frequently audited.
If your company conducts transactions with related parties, now is the time to verify whether you will be required to prepare local transfer pricing documentation for 2025 and fulfil the related reporting obligations. Work should not be delayed – preparing the documentation requires not only gathering the necessary financial and business data, but also conducting a detailed analysis and assessing whether the terms of the transactions comply with the arm’s length principle.
Failure to fulfil transfer pricing obligations may result in serious consequences, including penalties under tax and fiscal criminal law provisions, as well as an increased risk of the tax authorities challenging settlements in the course of an audit. It is therefore advisable to verify well in advance that all obligations have been correctly identified and that documentation will be prepared and submitted within the statutory deadlines.
Below, we outline the key deadlines for 2025 obligations and the potential consequences of failing to meet them.
Transfer pricing – key deadlines
As in the previous year, related parties are required to:
- Prepare local transfer pricing documentation – by the end of the tenth month following the close of the tax year. For taxpayers whose tax year coincides with the calendar year, this deadline falls on 31 October 2026.
- Submit transfer pricing information (TPR-C/TPR-P) – by the end of the eleventh month following the close of the tax year. For taxpayers whose tax year coincides with the calendar year, this deadline falls on 30 November 2026.
- Attach the master file (group documentation) to the local documentation – by the end of the twelfth month following the close of the tax year. Those whose tax year coincides with the calendar year must do so by 31 December 2026.
Fines of up to PLN 15 million for non-compliance
Failure to fulfil transfer pricing obligations may entail serious consequences. One of these is fiscal criminal liability for failing to submit transfer pricing information (TPR) on time. In such a case, the individuals responsible for fulfilling this obligation may face a fine of up to 240 daily rates which – at the maximum daily rate applicable in 2026 – could amount to approximately PLN 15.3 million.
The risks do not end there, however. Deficiencies or irregularities in transfer pricing documentation may also increase the likelihood of a tax audit being initiated, prolong its course, and lead to the tax authorities challenging the settlements applied with related parties.
It is therefore worth verifying the scope of obligations well in advance, preparing the required documentation, and ensuring the timely submission of TPR information. This is particularly important in light of the increase in tax audits and proceedings relating to transfer pricing observed in recent years.
Transfer pricing – how we can help
We support clients at every stage of fulfilling their transfer pricing obligations. We assist in identifying transactions subject to documentation requirements, prepare local and group transfer pricing documentation, draft TPR information, and advise on the correct determination of the arm’s length nature of settlements between related parties.
If you have any doubts as to whether documentation obligations apply to your company, or require support in preparing the documentation for 2025, please do not hesitate to contact our team.
Have questions? Contact us
