The Finance Ministry has published a long-awaited final version of a FAQ document on TPR transfer pricing report, entitled TPR Informacja o cenach transferowych – pytania i odpowiedzi, wrzesień 2020, MF. The document, which is dated September 2020, provides answers to taxpayers' questions on new transfer pricing reporting duties.

As a reminder, the TPR submission deadline has been moved to 31 December 2020 in connection with the COVID-19 pandemic.

The Finance Ministry answers various questions, including on how to:

  • report the actual transfer price where it is not yet known at the time of issuing the local file and the TPR report;
  • fill in the TPR report in the event of mid-year corporate merger;
  • fill in the TPR report where the residual profit split method has been used;
  • interpret the field Transaction value for financial transactions;
  • recognise recharges in the TPR report.

The final version of FM’s document comes in response to submissions from various stakeholders, including comments from WTS&SAJA during the tax consultation process which included earlier drafts of this document.

For the full list of the questions and answers, see this link (in Polish):

If this issue pertains to your business and you are interested in our assistance, please contact your WTS&SAJA consultant.

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