Back to publications We would like to remind you that the deadline for preparing the transfer pricing documentation (the so-called Master File) for 2021 is March 31, 2023. Therefore, we would like to highlight the key points related to the implementation of this obligation.
Entities Obligated to Prepare the Documentation
Entities that are consolidated using the full or proportional method and are required to prepare local transfer pricing documentation for 2021 must also include the group transfer pricing documentation, provided that they belong to a group of related entities:
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for which a consolidated financial statement is prepared;
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whose consolidated revenues exceeded PLN 200,000,000 or its equivalent in the previous fiscal year.
Deadline for Preparing the Master File
The deadline for preparing the group documentation has been extended to the end of the third month following the day after the deadline for submitting the local documentation statement. This means that taxpayers whose fiscal year ended on December 31, 2021, must prepare the group documentation by the end of March 2023.
Elements of the Master File
The group transfer pricing documentation should include the following information about the capital group:
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a description of the group,
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a description of significant intangible assets and rights within the group,
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a description of significant financial transactions within the group,
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financial and tax information about the group.
The detailed scope of the elements of the group documentation is regulated by the Ministry of Finance’s regulation from December 21, 2018, regarding transfer pricing documentation – in relation to corporate income tax and personal income tax.
Possibility of Preparing the Documentation by Another Entity
There are no obstacles to the group transfer pricing documentation being prepared by another entity within the group of related entities. However, it is important to note that the preparation of the Master File by another entity in the group does not exempt the taxpayer from the responsibility of ensuring that the documentation contains all necessary elements as indicated by the regulations.
Group Documentation in English
According to the regulations, the group documentation can be prepared in English. In such a case, the tax authority may, however, request that the group transfer pricing documentation be submitted in Polish within 30 days from the date of receiving this request.
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