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Minister of Finance extends the deadline for preparing transfer pricing documentation


Some taxpayers will surely heave a sigh of relief – on 15 March 2018 Regulation of the Minister Finance entered into force and extended by even 6 months the deadline for preparing tax documentation, filing a statement on preparation of the tax documentation and simplified CIT/TP and PIT/TP reports.  Pursuant to the regulations applicable to date, the above documents were to be prepared within the deadline for the filing of annual tax returns. In order to meet the expectations of businesses, the Ministry of Finance has prepared a Regulation wherein the deadline for preparing the above documents is extended up to the end of the ninth month following the end of the tax year.

As we noted many times, as of 1 January 2017 significant obligations with respect to documentation of transfer prices have been imposed on the taxpayers. The amendment of the CIT and PIT Acts has imposed on the taxpayers the obligation to prepare a local file (the elements of which only to a small extent correspond to the previous requirements), a master file unknown until now or a simplified report to be attached to an annual tax return, which should be complied with on the date of filing the annual tax return. Because of the workload and funds required to comply with those statutory obligations, and often also more difficult access to all information required in order to prepare documentation (especially as regards a master file), it may be difficult for the taxpayers to meet the required deadline.

This is why the Ministry of Finance has decided to extend the deadline up to the ninth month after the end of the tax year.

The extension of the discussed deadline covers the obligations which should be complied with in 2018 (with respect to tax documentation, a statement and a simplified report for the previous tax year, i.e. 2017) and in 2019 (with respect to transactions effected in 2018). In the case of PIT and CIT taxpayers whose tax year is the same as the calendar year, the new deadline is, respectively, the end of September 2018 and the end of September 2019.

We must add that the deadline relates only to the obligations set forth in the Regulation, that is, among others, attachment of a simplified CIT/TP and PIT/TP report to the annual tax return, however, the deadline for filing the latter has not changed. It means that the annual tax return should be filed by a PIT taxpayer by the end of April and by a CIT taxpayer by the end of the third month after the end of the tax year. In accordance with the Regulation, a simplified CIT/TP or PIT/TP report may be attached to the annual tax return later and will not require any correction or update of the annual tax return which has been previously filed.


Agnieszka Jasica-Skalbmierska, Tax Advisor, ATA Tax Sp. z o.o.