Transfer Pricing in Poland: The deadline for drawing up the Local File for 2020 is coming

published on 5 October 2021

As a rule, the Local File must be prepared by the end of the ninth month after the end of the financial year. However, in the case of the Local File for 2020 – similarly as in 2019, this deadline has been extended:

• until 30 September 2021 – for entities in the case of which the deadline expires between 1 February 2021 and 30 June 2021;
• by 3 months – for entities in the case of which the deadline expires between 1 July 2021 and 31 December 2021.

This means that in the case of taxpayers whose tax year is the same as the calendar year, the deadline for the preparation of transfer pricing documentation for 2020 expires on 31 December 2021. The new deadlines apply also to submission of the statement on preparing the Local File and applying arm's length prices as well as to filing the information on transfer pricing (TPR-C form).

Please remember that the Local File is prepared for uniform controlled transactions whose value, net of VAT, exceeds the following documentation thresholds in the financial year:

• PLN 10 million – for financial transactions or transactions in goods;
• PLN 2 million– for transactions in services and other transactions.
• PLN 100 thousand – for transactions made with an entity residing, established or having a management board in a territory or country applying harmful tax competition.