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Extension of deadlines for transfer pricing documentation obligations for 2021


On April 8, 2022, a governmental bill was introduced to the Sejm amending certain acts in order to automatise the processing of cases by the National Revenue Administration. According to the bill, the deadline for the submission of a transfer pricing report (TPR) and a statement on preparation of local transfer-pricing documentation will be extended:

  • until September 30, 2022 – where that deadline expires between January 31, 2022 and June 30, 2022;
  • by 3 months – where that deadline expires between July 1, 2022 and December 31, 2022.

For a large group of taxpayers whose financial year coincides with the calendar year, those time-limits will therefore expire on 31 December rather than 30 September. What is more, under the Anti-Crisis Shield 4.0, if the deadline for preparing a local file, the deadline for drawing the group documentation (the so-called Master file) will be extended until the end of the third month from the day following the day on which the deadline for submitting the statement expired. Thus, taxpayers whose tax year ends on December 31 will be required to prepare group documentation by the end of March 2023.

Please be reminded that related parties are obliged to prepare local transfer-pricing documentation (the so-called Local file) for a controlled transaction of a uniform nature, whose net value in the financial year has exceeded:

  • PLN 10 000 000 – in the case of commodity and financial transactions;
  • PLN 2 000 000 – in the case of service or other transactions.

Furthermore, taxpayers carrying out the so-called direct and indirect ‘haven transactions’ are also required to prepare tax documentation if the value of the transaction exceeds PLN 100 000 and PLN 500 000 respectively. However, related parties consolidated using the full or proportional method which are obliged to prepare local transfer-pricing documentation, are required to attach to this documentation their group transfer-pricing documentation if they belong to a group of related entities:

  • for which a consolidated financial statement is prepared;
  • whose consolidated revenue exceeded PLN 200 000 000 or its equivalent in the previous financial year.


Anna Skórska, Transfer Pricing Coordinator, ATA Tax Sp. z o.o.

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