More than a year ago, regulations on transfer pricing information (commonly known as TPR forms) were published and entered into force in both corporate and personal income tax. They shall apply to transfer pricing information submitted for the tax year starting after the date 31 December 2021, in practice 2022 and further (also those beginning in the middle of the calendar year).
one the changes to the TPR information were to be included in the form in question in the statement of tax documentation. Months passed, new versions of the forms were not published, the Ministry of Finance had to publish an additional communication on the submission of a declaration of drawing up local transfer pricing documentation in TPR-C and TPR-P information[1]. According to the communication, the statement was to be included in section F of the ‘old’ forms (i.e. version fourth).
Recently, models of TPR-C and TPR-P electronic documents were finally published in the version 5. For now, only the structure of the forms is available (available on the Public Information Bulletin of the Ministry of Finance)[2], but according to the announcement on the website of the Ministry of Finance, interactive forms are also to be provided (for the day 23 October not yet published).
However, the above-mentioned issue of the local tax documentation statement is not the only change. Among others, indicators for micro-entrepreneurs and small entrepreneurs have been identified in the general financial information section of the entity completing the form, and the authority to which the TPR information is to be submitted has been changed (now the head of the tax office competent for the taxpayer, not the Head of the National Tax Administration).
The Ministry of Finance’s communication can be found at the following address:
- https://www.podatki.gov.pl/ceny-transferowe/zmiany-w-prawie/publikacja-wzorow-dokumentow-elektronicznych-tpr-c-5-i-tpr-p-5-za-2022-rok/
- [1] The message can be found at: https://www.podatki.gov.pl/ceny-transferowe/wyjasnienia/komunikat-dotyczacy-zlozenia-oswiadczenia-o-sporzadzeniu-lokalnej-dokumentacji-cen-transferowych-w-informacji-tpr-c-oraz-tpr-p/
- [2] https://www.gov.pl/web/finanse/struktury-tpr