Tax Focus Ceny Eng

Transfer pricing: last call

When do related parties have to prepare transfer pricing documentation for 2022 and how will the scope of reporting change compared to previous years? Perhaps a review and clarification of this year’s transfer pricing obligations is in order, as this is the final bell for clarifying issues and preparing documentation.

Deadlines for preparation of transfer pricing documentation for 2022

This year, the Ministry of Finance has decided not to extend the deadlines for fulfilling transfer pricing obligations. This means that the deadlines resulting directly from income tax acts will apply.

Accordingly, for entities whose tax year is the same as the calendar year, the deadline for:

  • Preparation of the Local File is 31 October
  • Submission of transfer pricing information is 30 November
  • Attaching the Master File to the Local File is 31 December

Statement on the preparation of the Local File

It should also be noted that from this year, the statement on the preparation of the Local File is included in the TPR-C form. In previous years, these documents had to be submitted separately.

New scope and signing rules for TPR-C forms

The changes to the TPR-C form, including the scope of reporting, have already been covered in detail in previous issues of Tax Focus.

In addition, please note the revised rules for the signing of TPR-C forms. Under these new rules, the form must be signed by:

  • A natural person in the case of a related entity that is a natural person
  • A person authorised to represent a branch of a foreign business entity in Poland
  • The manager of the entity, and if the entity is managed by a multi-member body, by a designated person from that body

– however, the form may not be signed by an attorney, unless the attorney is an advocate, attorney-at-law, tax advisor or certified auditor.

In the meantime, please remember that our tax team is available to assist clients with their transfer pricing obligations.

Questions? Contact us

Katarzyna Pustułka

Jakub Dittmer

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