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Amendments to the TPR-related regulations


Most taxpayers are currently finalising their transfer pricing documentation for 2020. Meanwhile, the Finance Ministry has prepared another proposal for changes. The draft regulations of the Minister of Finance, Funds and Regional Policy amending the regulations on transfer pricing reports - with respect to corporate income tax (CIT) and personal income tax (PIT), respectively - have been published on the website of the Government Legislation Centre.

The purpose of the draft regulations is to make it easier for taxpayers to complete and submit the TPR form and enhance the effectiveness of transfer pricing information analysis. The planned modifications are also related to the entry into force of the amendment to the CIT Act, which included regulations in the field of transfer pricing, notably in terms of reporting the so-called ‘tax haven transactions’[1].

The published draft regulations provide in particular for:

  • Adding information on the value of the reportable transaction per country of residence or management of the contractor,
  • Adding information on the type of transaction reported and the country of the beneficial owner (in the case of tax haven transactions),
  • More detailed explanations regarding completion of the TPR form in relation to the selected tax identifier,
  • Changes to the explanations regarding completion of the TPR form in relation to the code for transaction categories "Other transactions - sale" and "Other transactions - purchase".

The amended provisions of the Regulations will apply for the first time to transfer pricing returns for the tax year beginning after 31 December 2020.

At the same time, we would like to remind you that the deadline for filing the TPR form for taxpayers whose tax year elapsed on December 31, 2020 expires at the end of December of this year. The above follows from the Act of March 30, 2021 amending the Excise Duty Act and certain other acts, whereby the deadline for fulfilling the TPR reporting obligations has been extended.


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

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[1] The Act of November 28, 2020 amending the Personal Income Tax Act, the Corporate Income Tax Act and the Law on flat-rate income tax on certain income of natural persons and certain other acts.