The Ministry of Finance has provided a test interactive TPR-C form to be consulted.
Transfer pricing provisions applicable from 1 January 2019, introduce an obligation for related parties to submit transfer pricing information on a basis Article 11t Corporate Income Tax Act[1] and Article 23zf Personal Income Tax Act[2].
This information shall be drawn up on the basis of the model of the electronic document set out in the Public Information Bulletin on the website of the body office serving the minister responsible for public finances.
As a result of the work carried out so far, diagrams (logical structures) of transfer pricing information have been made available: https://www.gov.pl/web/finanse/struktury-tpr .
At the same time, in order to reduce administrative costs, especially for small and medium-sized enterprises, and to implement the requests made by the participants of the Transfer Pricing Forum, the Ministry of Finance prepared an interactive form to enable taxpayers to comply with this reporting obligation without the need to purchase additional software.
The purpose of the consultation is to obtain the advice of taxpayers on the substantive correctness and logic of the interactive transfer pricing information form for corporate income tax (TPR-C). The comments will be taken into account in the preparation of a similar interactive form for personal income tax (TPR-P).
When the form is downloaded, a short form shall be displayed where there is a place to identify the originator and the subject of the information, and 2 questions. The question arises as to whether all contributions to transactions and methods referred to in the Act and the Regulation will be received separately?
Feedback and comments we can report to 21 October. The TPR-C interactive test form can be downloaded below in pdf.
Author: Leszek Dutkiewicz, partner Russell Bedford Poland. Associated with the company from 2011. Director of RBP office in Katowice. In years 2008 – 2011 worked for leading consulting companies (Ernst&Young, KPMG, BDO) providing tax advisory services.
He specializes in tax and economic law, primarily in international tax law, tax proceedings, VAT and transaction prices. Author of a publication on tax, civil and international law issues. Lecturer in tax law training. He has legal education, in 2008 graduated from the Faculty of Law and Administration of the Jagiellonian University.