Back to insights
Tax updates

Obligation to submit transfer pricing information – news from the Ministry of Finance

On 28 April 2020 On the Tax Portal, the reply of the Ministry of Finance, following a post request, concerning the obligation to submit transfer pricing information (hereinafter: TPR) by a tax group, as well as by entities carrying out domestic transactions with related parties whose value does not exceed the…

On 28 April 2020 On the Tax Portal, the reply of the Ministry of Finance, following a post request, concerning the obligation to submit transfer pricing information (hereinafter: TPR) by a tax group, as well as by entities carrying out domestic transactions with related parties whose value does not exceed the…

On 28 April 2020 On the Tax Portal, the reply of the Ministry of Finance, following a post request, concerning the obligation to submit transfer pricing information (hereinafter: TPR) by a tax group, as well as by entities carrying out domestic transactions with related parties whose value does not exceed the statutory documentation thresholds.

Reporting of transfer prices by the tax group

According to the position presented by the Ministry of Finance in the case of taxpayers with tax status of the capital group, the entities obliged to submit transfer pricing information will be companies forming a tax capital group, not the group itself.

Reporting of transfer prices by entities carrying out domestic transactions whose value does not exceed the statutory thresholds

For taxable persons carrying out domestic transactions with related parties whose value does not exceed the statutory thresholds set out in Article 11k(2) Corporate Income Tax Act, there will be no obligation to submit transfer pricing information.

On the other hand, it should be stressed that TPRs will be obliged to provide information to entities that carry out transactions that exceed the quota thresholds but benefit from exemption from the obligation to draw up tax records.

The full content of the parliamentary inquiry and the answers of the Minister of Finance is available at:

https://www.podatki.gov.pl/ceny-transferowe/wyjasnienia/obowiazek-skladania-informacji-o-cenach-transferowych-tpr/

In addition, we remind you that interactive TPR forms are available at:

https://www.podatki.gov.pl/cit/e-deklaracje-cit/formularze-cit/

Continue exploring our insights.

View all insights
Tax updates

Changes to PIT and CIT tax rules

Increasing the PIT tax brackets, limiting the flat tax, and changes concerning CIT taxpayers may affect the cost-effectiveness of different taxation options.

Tax updates

Reporting of the result on TPR-C transactions only for the tax year to which the information relates – current position of KIS

The Director of KIS confirmed that the TPR-C should only show the transaction result for the tax year covered by the information.

Tax updates

Planned changes to transfer pricing legislation

Given the increasing number of intra-group transactions, the need to amend transfer pricing issues is increasingly important.