This is to let you know that, on 22 June 2020, the President signed a law called the Act of 19 June 2020 on interest support for credit facilities to businesses affected by COVID-19 consequences and on simplified arrangement approval process in connection with COVID-19 (“Shield 4.0“).

You may remember that the new Article 31z as amended by Shield 4.0 provides that the deadline to file transfer pricing reports (TPR) and local file representations is extended:

  • until 31 December 2020 where the original deadline expires between 31 March 2020 and 30 September 2020;
  • by 3 months where the original deadline expires between 1 October 2020 and 31 January 2021.

A practical consequence of this for taxpayers whose tax years coincide with the calendar year is that the extended deadline for the filing of TPR reports and local file representations will fall on 31 December 2020. What is more, if such taxpayers make use of this extension, they will have a new deadline for the filing of their master files, i.e. until 31 March 2021.

Another novelty is that Article 32(1) of Shield 4.0 permanently disapplies transfer pricing regulations with respect to transactions between public medical schools of higher education and healthcare providers established by them.

For more on the relaxed transfer pricing regulations introduced under Shield 4.0, you may want to see this link (in Polish):

https://www.podatki.gov.pl/ceny-transferowe/zmiany-w-prawie/ulatwienia-dla-przedsiebiorcow-w-obszarze-cen-transferowych-w-ramach-tarczy-4-0/

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

This blog post provides general information and is designed to keep you up-to-date with changes in tax law, tax rulings and interpretations, case law development and interesting commentaries. Doradztwo Podatkowe WTS&Saja shall not be held legally liable for any acts or omissions that follow from the contents hereof.