Related entities which are subject to the obligation to submit TPR information are companies forming PGK, and not PGK as a taxpayer. Therefore, each of the companies forming PGK is separately subject to the obligation to submit TPR information in relation to the transactions it concludes. According to art. 11n pkt. 4 of the Act, controlled transactions between companies within PGK are exempt from the documentation obligation. Transactions exempted from the documentation obligation under Art. 11 n point 4 of the Act were not indicated in Art. 11t of the Act, concerning the obligation to submit information on TPR, therefore these transactions are not covered by this obligation. As a result, companies belonging to PGK are obliged to indicate in the TPR information controlled transactions concluded with affiliates outside PGK only in the scope of transactions covered by the obligation to prepare local transfer pricing documentation.

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