Deadlines for the preparation of transfer pricing documentation for 2025

Controlled transactions exceeding the amounts specified in Articles 11k and 11o of the CIT Act (not benefiting from the exemptions listed in Article 11n of the CIT Act), concluded by CIT taxpayers with related parties (in accordance with Polish transfer pricing regulations), should be included in the transfer pricing documentation. These transactions must also be reported in the special transfer pricing declaration, so called TPR-C.

TPR-C – information on transfer pricing

Part of the TPR-C for 2025 will once again be a statement that the transfer pricing documentation (local file) has been prepared in accordance with the actual state, and that the transfer prices set in intercompany transactions covered by this documentation are determined on terms that would be agreed between unrelated entities on the market. 

The TPR-C must be signed by:

• the head of the unit (and in the case where the unit is managed by a multi-person body by a designated person who is part of that body) or 

• a person authorized to represent a branch of a foreign entrepreneur in Poland or 

• a natural person (in the case of an entity that is a natural person). 

The Transfer Pricing Information (TPR-C) may also be signed by an attorney with the powers tax advisor, attorney-at-law, legal advisor or statutory auditor.  

The signed TPR-C must be submitted to the tax office competent for the taxpayer. 

An important issue required for the correct submission of the TPR is that the person appointed to sign the TPR-C has a valid qualified electronic signature containing a Polish PESEL number or NIP.

Also, submitting-C TPR requires the registration of UPL-1, i.e. the power of attorney to sign the declaration submitted by means of electronic communication. UPL-1 should be signed in accordance with the rules of representation of a given entiTPR-C – information on transfer pricing

Part of the TPR-C for 2025 will once again be a statement that the transfer pricing documentation (local file) has been prepared in accordance with the actual state, and that the transfer prices set in intercompany transactions covered by this documentation are determined on terms that would be agreed between unrelated entities on the market. 

The TPR-C must be signed by:

• the head of the unit (and in the case where the unit is managed by a multi-person body by a designated person who is part of that body) or 

• a person authorized to represent a branch of a foreign entrepreneur in Poland or 

• a natural person (in the case of an entity that is a natural person). 

The Transfer Pricing Information (TPR-C) may also be signed by an attorney with the powers tax advisor, attorney-at-law, legal advisor or statutory auditor.  

The signed TPR-C must be submitted to the tax office competent for the taxpayer. 

An important issue required for the correct submission of the TPR is that the person appointed to sign the TPR-C has a valid qualified electronic signature containing a Polish PESEL number or NIP.

Also, submitting-C TPR requires the registration of UPL-1, i.e. the power of attorney to sign the declaration submitted by means of electronic communication. UPL-1 should be signed in accordance with the rules of representation of a given entity. 

Who needs to prepare transfer pricing documentation?

Transfer pricing documentation should include transactions (of a homogeneous nature) the value of which exceeds: 

• PLN 10,000,000 – in the case of financial transactions and transactions involving the sale or purchase of products, goods, materials, etc., 

• PLN 2,500,000 – in the case of financial transactions concluded with an entity from a tax haven (related or unrelated), 

• PLN 2,000,000 – in the case of service transactions and other transactions, 

• PLN 500,000 – in the case of non-financial transactions concluded with an entity from a tax haven (related or unrelated). 

What are the deadlines for preparing transfer pricing documentation?

The deadlines for the preparation of transfer pricing documentation for 2025 are as follows: 

• transfer pricing documentation (local file) with analyses of comparative (benchmarking) data - by the end of the 10th month after the end of the tax year, 

• transfer pricing information (TPR-C) - by the end of the 11th month after the end of the tax year, 

• group transfer pricing documentation (master file) - by the end of the 12th month after the end of the tax year. 

The deadline for submitting a CBC-P notification is 3 months from the end of the financial year of the group, and the deadline for the possible submission of a CBC-R report is 12 months from the end of the financial year of the group. 

Author: 
Mateusz Janiak, Senior Consultant in the Transfer Pricing Team 

Mateusz has several years of professional experience covering a wide range of clients, including FMCG, IT, automotive, manufacturing and distribution. He has completed numerous projects on transfer pricing documentation, benchmarking and compliance analyses. His experience also includes specialized advice in the area of transfer pricing, as well as support in obtaining APA and MAP. Mateusz is a graduate of Finance and Business Accounting at the Poznań University of Economics.