The 17th Transfer Pricing Forum (TPF) was held on 15 June 2023 with an active participation of Doradztwo Podatkowe WTS&SAJA Sp. z o.o.

A short report on issues addressed at TPF will be the subject of our next newsletter. Today we wish to touch on a topic that will probably be of greatest interest for taxpayers required to prepare transfer pricing documentation for tax year 2022, i.e. the status of development work on form TPR(5).

The following information was given by representatives of the Ministry’s Income Taxes Department:

  • Work is in progress to amend the transfer pricing report (TPR) regulations so that they will reflect changes in income tax statutes (including the change of authority with which TPR is to be filed, the addition of a requirement to represent that TP documentation has been prepared, etc.).
  • The new regulations (and so the new TPR form) will not require disclosing the ratio of operating expenses of business with related parties to total operating expenses.
  • New schemas for TPR forms will be published 2 or 3 days after commencement of the amended regulations.
  • The new forms will not be provided as interactive PDF files. Instead, they will be available in a new browser-based tool which is expected to be launched in July 2023. Use of the eDeklaracje gateway for filing purposes will become possible 2 weeks after publication of the form.
  • There are plans to revise TPR Manual to make it simpler and more uniform, and include additional questions and answers. The revised TPR Manual is scheduled to be published in September 2023. Also, all manuals are supposed to be grouped in a dedicated on-line tab.

If this issue pertains to your business and you are interested in our assistance, please contact us.

This blog post is provided for general information purposes to keep you up-to-date with changes in tax law, tax rulings by authorities, case law of courts and interesting commentaries. Doradztwo Podatkowe WTS&SAJA shall not be held legally liable for any acts or omissions resulting from reliance on such information.