Polish Transfer Pricing Advisory Services for Multinational Groups
Stay compliant with Polish Transfer Pricing regulations – without disrupting your global framework
ICT’s expert support for CFOs, tax managers, and accountants in multinational enterprises.
We ensure your transfer pricing documentation meets Polish requirements while aligning with your group’s global standards.
Why Transfer Pricing compliance matters
Polish tax authorities impose strict obligations on companies engaged in controlled transactions. Even if your Group prepares Local File abroad, you must still comply with Polish Local File requirements, TPR reporting, and arm’s length principles.
Failure to comply can result in:
- financial penalties up to millions of PLN,
- increased audit risk,
- reputational damage.
Our mission is to help you avoid these risks and maintain full compliance with Polish transfer pricing regulations.
Remember that having a Master File alone is not sufficient. You must also prepare a Local File compliant with Polish regulations.
Our expertise
ICT is a specialized advisory firm focused exclusively on transfer pricing and international tax compliance. With years of experience supporting capital groups, we combine:
- deep knowledge of Polish tax law including OECD transfer pricing guidelines,
- incorporation the current approach of tax authorities, the Ministry of Finance, and administrative court rulings in the transfer pricing documentation,
- practical solutions for cross-border transactions.
Our services in detail
Local File
We prepare Polish-compliant Local File documentation for all controlled transactions, ensuring consistency with your global Master File.
Includes:
- transaction analysis,
- functional and risk profiles,
- financial data integration.
Benchmarking & Comparability Analysis
We perform robust benchmarking studies using databases also used by tax authorities.
Benefits:
- accurate arm’s length pricing,
- reduced audit exposure.
Transfer Pricing Policy development
We design transfer pricing policies tailored to your group structure, ensuring:
- transparency,
- compliance with Polish and OECD standards,
- alignment with global documentation.
TPR Reporting & Compliance
We handle TPR-C form preparation and electronic submission, meeting all Polish reporting obligations.
Business Restructuring Support
We assist with:
- compensation calculations,
- documentation for business restructurings,
- risk assessment for intra-group changes.
Advance Pricing Agreements (APA)
Full support in:
- negotiating APAs,
- managing Mutual Agreement Procedures (MAP),
- securing long-term certainty for your pricing policies.
Why choose ICT?
- Specialized Focus: Transfer pricing is our core expertise.
- Proven Track Record: Trusted by multinational groups across industries.
- Regulatory Insight: We stay ahead of evolving Polish tax laws.
- Tailored Solutions: Adapted to your global documentation framework.
Contact us!
Ensure full compliance with Polish transfer pricing rules today.
INSTYTUT CEN TRANSFEROWYCH Sp. z o.o.
phone: (+48) 22 114-06-56
e-mail: biuro@ict.org.pl
Michał Mika
Partner
mobile: (+48) 535 857 067
e-mail: mmika@ict.org.pl
Polish Transfer Pricing Advisory Services for Multinational Groups
Ensure full compliance with Polish transfer pricing rules today.
Michał Mika
Partner
mobile: (+48) 535 857 067
e-mail: mmika@ict.org.pl
Contact with us.
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Transfer Prising FAQ
Why do we need Polish Local File if we already have a Master File?
Polish tax law requires Local File for all controlled transactions involving Polish entities, even if your group prepares a Master File. The Local File must include detailed financial data, functional analysis, and benchmarking specific to Poland.
What are the consequences for non-compliance with Polish transfer pricing regulations?
Sanctions can include:
- financial fines
- additional tax assessments.
You are also exposed to reputational damage.
How does ICT ensure alignment with our global documentation?
We adapt your existing Master File and global transfer pricing policies to meet Polish requirements, ensuring consistency and compliance without duplicating work.
What is TPR reporting and why is it important?
TPR (Transfer Pricing Report) is an annual electronic submission required by Polish tax authorities. It includes detailed information on controlled transactions and compliance with the arm’s length principle. Incorrect or late submission can trigger audits by tax authorities.
Do you provide benchmarking studies?
Yes. We perform benchmark studies using databases also used by tax authorities, ensuring your pricing is defensible and compliant.
Can you assist with Advance Pricing Agreements (APA)?
Absolutely. We manage the entire APA process—from application to negotiation—providing certainty and reducing future audit risk.
How quickly can you prepare Local File documentation?
Depending on transaction complexity and their quantity, we typically deliver complete documentation within range of 1 to 4 weeks, ensuring timely compliance.
What are the deadlines for fulfilling the obligations?
- Local file and benchmarking analysis – 10 months after the end of the tax year.
- TPR – 11 months after the end of the tax year.
