On Friday, the Finance Ministry announced on government website (see here) that legislation was signed with a view to deferring the due date for the filing of transfer pricing report TPR.
The legislation was officially published on 27 Nov 2023 (see here).
Contrary to earlier reports, the signed document defers the due date for TPR filing by 2 months, i.e. to 31 January 2024, where the due date would otherwise fall within the period from 30 November 2023 to 31 December 2023. The deferral applies to forms applicable to tax years after 31 December 2021.
Taxpayers are advised to use those two additional months, for example, to make sure that the person designated to sign form TPR-C as per the representation matrix has:
- a PESEL code,
- access to qualified electronic signature,
- authorisation granted on form UPL-1 and registered with the Finance Ministry.
Please note that, as of this year, the form contains a statement by the TPR-C signatory that the local file has been prepared in accordance with the facts while the reported transfer prices have been established on such terms as would be established between unrelated parties, and that – for transactions with entities based in tax havens – the reported prices are as would be established between unrelated entities that are not residents of any country or territory engaging in harmful tax competition.
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.