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Extension of deadlines for the performance of obligations related to transfer pricing documentation.


On February 25, 2021, the Sejm adopted the act amending the Act on excise duty and certain other acts. As in the previous year, related entities will be given more time to perform the obligations related to transfer pricing documentation.

Pursuant to the Act, which is currently being processed in the Senate, the deadline for submitting transfer pricing reports (TPR) and the declaration on the preparation of local transfer pricing documentation is extended:

  • until September 30, 2021 – if the original deadline expires between February 1, 2021 and June 30, 2021;
  • by 3 months – if the original deadline expires between July 1, 2021 and December 31, 2021.

Consequently, in case of taxpayers whose financial (tax) year coincides with the calendar year, the deadlines will expire on December 31, and not September 30. Furthermore, in accordance with the so-called ‘Anti-Crisis Shield 4.0’, in case of extended deadlines for submitting local transfer pricing, the deadline for preparing the group documentation (the so-called ‘Master file’) has been extended until the end of the third month from the day following the day on which the deadline for submitting the statement expired. It means that the taxpayers whose financial (tax) year ends on December 31 will be required to prepare group documentation by the end of March 2022.

Please be reminded that since January 1, 2019 related parties have been obliged to prepare local transfer-pricing documentation (the so-called ‘Local file’) for a controlled transaction of a uniform nature whose net value has exceeded the following thresholds in a financial year:

  • PLN 10 000 000 – in case of commodity and financial transactions;
  • PLN 2 000 000 – in case of a service or another transaction.

However, related parties consolidated using the full or proportional method which are obliged to prepare local transfer-pricing documentation, must enclose a group transfer-pricing documentation if they belong to a group of related entities:

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

The draft was submitted for further legislative work.


Anna Skórska, Tax Consultant, ATA Tax Sp. z o.o.

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