Pursuant to Article 77 point 62 of the Act of 19 June 2020 on subsidies to interest rates on bank loans granted to entrepreneurs affected by the effects of COVID-19 and on simplified procedure for the approval of the agreement in connection with the occurrence of COVID-19 (hereinafter referred to as “Shield 4.0.”), a new wording of Article 31z of the Act of 2 March 2020 on special solutions related to the prevention, prevention and combating of COVID-19, other infectious diseases and crisis situations caused by them has been added, introducing the extension of deadlines:

  1. to submit transfer pricing information (TPR), and
  2. to make a statement on the preparation of local transfer pricing documentation
  • by 31 December 2020. – if this deadline (as specified in the Personal Income Tax Act or Corporate Income Tax Act) expires between 31 March 2020 and 30 September 2020,
  • by 3 months – if this deadline (specified pursuant to the provisions of the Personal Income Tax Act or the Corporate Income Tax Act) expires in the period from 1 October 2020 to 31 January 2021.
  1. to attach group transfer pricing documentation to local documentation
  • until the end of the third month following the day on which the extended time limit for the submission of the statement that the local transfer pricing documentation has been prepared has expired.

The main purpose of postponing the above mentioned deadlines is to make it easier for entrepreneurs to meet their transfer pricing obligations and to adapt them to the changed deadlines for preparing and approving financial statements.

The new regulation contained in Disc 4.0. extends the scope of entities covered by the extension of the above mentioned deadlines in the area of transfer pricing to all obliged entities. Therefore, it is a much more common instrument than the previous solutions contained in the Shield 1.0. and 2.0., which extended the deadlines only to entities whose tax year was different than the calendar year.