On 31 October 2025, the Finance Ministry published what is already the sixth release of its Q&A advisory brochure which concerns transfer pricing reporting compliance through use of form TPR (Informacja o cenach transferowych).

What’s new in the current release?

As a major change, the document explains a new method to translate currency amounts for financial transactions. This concerns the following boxes on the form:

  • „Wartość zadłużenia” (Amount of debt),
  • „Kwota odsetek (memoriałowo)” (Amount of interest (accruals basis)), and
  • „Kwota odsetek (kasowo)” (Amount of interest (cash basis)).

According to the brochure, such currency amounts should be translated into PLN using the National Bank of Poland mid rate prevailing on the last business day of the period for which form TPR is filed. Previously the Finance Ministry advised in the earlier versions of the brochure that the amounts should be reported as per taxpayer’s books of account.

The Ministry say that having homogeneous currency translation rules will simplify TPR reporting.

We believe taxpayers will not find the process simpler where they have to apply an external translation method instead of simply relying on their books of account.

Is it possible to continue to report under the “old” rules?

The Ministry said that previous rules may still be used to report in accordance with the TPR Advisory Brochure 2024 (release 5).

Businesses will do best to stick to the old rules for the following reasons:

  • Reporting on the basis of your books of account is the simplest solution.
  • Disclosing any information on Form TPR that is inconsistent with your local file or with the facts is a fiscal offence punishable under Article 80e of the Fiscal Penal Code by a financial penalty of up to 720 day fines.
  • TPR Advisory Brochure is merely advisory in nature and as such is not an official public tax ruling or official tax guidance for the purposes of the Tax Code Act of 29 August 1997. Following such an advisory brochure does not offer any official assurance or comfort.

What is the due date to file TPR for 2024?

For entities whose tax year coincides with the calendar year, form TPR for 2024 should be filed by 1 December 2025.

For all other entities the due date is end of 11th month following the end of the reported tax year.

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