Poland: Extending deadlines for compliance with transfer pricing

published on 2 March 2018

• preparing the transfer pricing documentation (Local File and Master File),
• submitting to a tax office a declaration that the TP documentation is ready,
• enclosing a CIT/TP summary report to the tax return for the fiscal year.

To simplify the tax system and taking into consideration significant interest of the taxpayers, the deadlines are planned to be extended to the last day of the ninth month after the end of the fiscal year, and not to be the same as the deadline for filing a tax return, like it is now. The amended regulations are expected to apply to the obligations that arise in 2018 (i.e. to the transfer pricing documentation, the declaration and the summary report for 2017) and in 2019 (i.e. to the transfer pricing documentation, the declaration and the summary report for 2018).

With the extension of the deadline for the preparation of transfer pricing documentation by six months taxpayers will not have to act under time pressure, which will surely let them meet their obligations more accurately.

Furthermore, the Ministry of Finance informed the public that at the same time it was working on an amendment that would allow to significantly reduce and simplify taxpayers' documentation obligations. Since the changes will be favourable to taxpayers, the new regulations are planned to be implemented retroactively with effect from 1 January 2018. We hope that the changes will minimise the amount of required data, thereby reducing the workload and the related expenses.

We will keep you informed about the progress of the work on the new, more favourable legislation. If you would like more information on that topic, please let us know – we will be happy to help you.