This is to let you know of the publication of the Finance Minister’s regulation of 16 September 2023 amending the transfer pricing report regulation. The regulation sets out the disclosures and representations to be made in the transfer pricing report (informacja o cenach transferowych) as well as giving instructions on how to fill it out.

The main changes are as follows:

  • the regulation has been amended to take into account the repeal of the law regarding so-called indirect transactions with tax havens,
  • the regulation does away with the ratio of costs of operations with related parties to total operating expenses.

Let us remind you that the transfer pricing report for 2022 will not be filed on the interactive PDF form but via an on-line tool available from Finance Ministry’s website. In addition to the web form, the Finance Ministry is supposed to also publish new TPR guidance with frequently asked questions and answers to them.

Unfortunately, the new form has not been made available by the Finance Ministry yet, so it is not yet possible to file TPR for 2022. We will keep you updated on any developments in this regard.

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.