We would like to remind you of the upcoming deadlines for the preparation of TP (transfer pricing) documentation for the tax year 2023.
TP documentation
Obliged entities prepare local TP documentation for a controlled transaction of a homogeneous nature with a value above:
- PLN 10,000,000 – in the case of a commodity transaction;
- PLN 10,000,000 – in the case of a financial transaction;
- PLN 2,500,000 – in the case of a financial transaction with a “tax haven” entity;
- PLN 2,000,000 – in the case of a service transaction/other transaction;
- PLN 500,000 – in the case of a transaction other than a financial transaction with a “tax haven” entity.
The local TP documentation (together with benchmarking analyses) should be prepared by the end of the tenth month after the end of the tax year. In the case of entities with a tax year identical to the calendar year, it will be the end of October.
On the other hand, by the end of the twelfth month after the end of the tax year, a master file must be prepared. In the case of entities with a tax year identical to the calendar year, it will be the end of December.
TPR-C
The transfer pricing information (TPR-C) is submitted by the end of the eleventh month after the end of the tax year In the case of entities with the same tax year as the calendar year, it will be the end of November.
Let us remind you that in the case of companies, the information is signed by the head of the entity (within the meaning of the Accounting Act), and if the entity is managed by a multi-member body – by a designated person who is a member of this body. It is not permissible for this information to be signed by an attorney, except for an attorney who is an advocate, legal advisor, tax advisor or statutory auditor.
It is also worth remembering that appointing a person who is a member of a multi-person body to sign the transfer pricing information does not release other members of this body from liability for failure to submit this information.
CBC
The CBC-P notification should be submitted within 3 months from the end of the reporting financial year of the group of entities. A possible report (CBC-R) is submitted within 12 months from the end of the reporting financial year.
