A new revision of forms TPR-P and TPR-C has been published by the Finance Ministry in the Public Information Bulletin. The new forms are used to file transfer pricing information for tax years starting after 31 December 2019. For the related guidance on the Finance Ministry’s website (in Polish), click the link below:



Major changes over the previous revision:

  • An option has been added to freely describe the controlled transaction (previously the choice was only from a close-ended list).
  • Rounding rules have been homogenised to require a precision of thousands.
  • Loan debt disclosure has been simplified (the figure to disclose is balance at end of tax year).
  • Additional information is required for financial transactions: interest charged/due and interest paid/received.
  • Substantially more information needs to be disclosed in TPR in the case of non-corporate partnerships.
  • The restructuring disclosures section has been significantly extended, with 13 categories now distinguished, such as merger, division and acquisition, share exchange, change of functional profile, transfer of intangibles, transfer of employees with termination of their previous contracts and conclusion of new ones, transfer (including as equity capital) of part of going-concern business.

You may recall that the transfer pricing information report must be submitted to the Head of the National Revenue Administration by:

  • entities required to prepare local files, in which case the report must comprise all transactions from such a file; and
  • entities entering with domestic entities into controlled transactions that are exempt from the local file documentation requirement.

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.
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