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Deadlines for complying with transfer-pricing documentation obligations expire soon


Since January 1, 2022, new deadlines for transfer-pricing documentation obligations have been in force. For companies whose tax year corresponds to the calendar year, the deadline for preparing local documentation is the end of October 2023 and for filing TPR information is the end of November 2023. It is therefore the last moment for the taxpayers to comply with the obligations and avoid potential sanctions for failure to comply with documentation obligations.

Local documentation

Related entities are obliged to prepare an electronical version of local transfer-pricing documentation by the end of the tenth month after the end of the fiscal year.

Please be reminded that local documentation must be prepared for controlled transaction of uniform nature, whose net value in the financial year 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.

Taxpayers carrying out tax haven transactions are also required to prepare tax documentation , if the value of the transactions exceeds:

  • PLN 2 500 000 in the case of financial transactions;
  • PLN 500 000 in the case of services other that financial transactions.

Information on transfer pricing

Moreover, related parties obliged to prepare local transfer-pricing documentation, are required to submit transfer-pricing documentation to the appropriate tax office by the end of the eleventh month after the end of the fiscal year.

Since 2022, the TPR return has included a statement in which taxpayers present that their local documentation is true and accurate and that the transfer prices covered by the documentation have been determined in accordance with the arm’s length principle.

Group documentation

Related parties whose financial statements are consolidated using the full or proportional method are obliged to prepare a Local File and attach to it their group transfer -pricing documentation by the end of the twelfth month after the end of the tax year if they belong to a group of related entities:

  • for which a consolidated financial statement is being prepared;
  • whose consolidated revenues 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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