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Poland: Interactive transfer pricing form, Local file

Poland: Interactive transfer pricing form, Local file

Poland’s tax authority released an interactive version of a transfer pricing form, TPR-C.

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The TPR-C form must be submitted by taxpayer entities required to prepare the Local file or that have entered into domestic related-party transactions that are exempt from transfer pricing documentation requirements under Article 11n(1). The deadline for submitting the TPR-C form by corporate taxpayers is generally nine months from the end of the tax year for which the declaration is due. Under provisions of the "anti-crisis shield" measures, the deadline for submitting the TPR-C declaration for 2019 (generally due before 30 September 2020) has been extended to 30 September 2020.

The interactive TPR-C form (authenticated with a qualified electronic signature) is  submitted via eDeklaracje website.

Following the consultation on a draft version of the form, changes are reflected in the final version of the TPR-C form, such as:

  • A possibility to indicate more than one country of the contractor's location for one type of transaction
  • The addition of section F (under the topic "More information") when an additional explanation may be provided by the taxpayer
  • When selecting the type of transaction as either low value-adding services or financial transactions under the safe harbor simplification rule, requiring that the taxpayer indicate whether there were transfer pricing adjustments


KPMG observation

Tax professionals have noted that to a certain extent, the changes reflected in the final version of the form could make it easier to manage the TPR-C filings. In preparing the TPR-C form for submission, taxpayers must provide certain key information related to transactions entered into with related parties, including the results of benchmarking studies; thus, taxpayers may want to consider preparing the Local file for 2019 in advance.

Read an April 2020 report [PDF 233 KB] prepared by the KPMG member firm in Poland

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