Since 1 January 2019, the amended transfer pricing regulations have been in force.

One of the new obligations imposed on taxpayers is to submit information TPR-C/ TPR-P instead of CIT-TP/ PIT-TP.

Entities which execute transactions with related entities exceeding the transaction thresholds specified in the regulations are obliged to report TPR information to the Head of the National Revenue Administration: 2 million or 10 million PLN net. Entities which execute transactions which were exempted from the obligation to document them on the basis of Article 11n of the Corporate Income Tax Act / 23 of the Personal Income Tax Act are also obliged to submit TPR information.

The TPR form should be submitted by the end of the 9th month after the end of the financial year. The deadline for submitting transfer pricing information is therefore the same as the deadline for preparing local transfer pricing documentation. The introduced deadline is due to the fact that the reported information will largely result from the prepared local transfer pricing documentation.

It should be noted that the content of the form itself differs significantly from the CIT-TP/ PIT-TP declaration submitted so far. Apart from basic data on the entity submitting the TPR, the form requires indicating, among other things:

  1. all controlled transactions which exceeded the documentation thresholds specified in the regulations,
  2. the transfer price verification methods applied,
  3. the source of comparative data and the type of comparison made,
  4. he results of comparative analysis for particular types of transactions.

In order to make it easier for taxpayers to prepare the information, the Ministry of Finance prepared a draft document “Questions and answers concerning information TPR-C and TPR-P for 2019”.

The document was prepared in order to make it easier for taxpayers to submit information TPR-C and TPR-P for 2019.

Tax consultations for the draft document will last until 22 May 2020.


Author: Beata Rawa – Transfer Pricing Manager