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/