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Poland: Decree on information to include in transfer pricing documentation

Poland: Transfer pricing documentation

A decree on information that should be included in the statutory transfer pricing documentation—effective 3 October 2017—has implications for entities concluding related-party transactions. The decree specifies, in detail, content that must be included in the transfer pricing documentation.


Related content

Provisions of Poland’s transfer pricing documentation rules provide only in general terms, information to be included in the documentation concerning taxpayer transactions with related parties. The decree describes information to be included in the transfer pricing documentation.

Components of transfer pricing documentation

Specific information that taxpayers must include in their transfer pricing documentation includes information concerning:

  • Local file
  • Benchmarking study
  • Master file

The decree also defines concepts that are further used to describe the formal requirements for the Local file, benchmarking study, and Master file, such as:

  • Functional analysis
  • Functional profile
  • Value-added chain

The decree also focuses on information about: (1) value chain in transactions between related parties that create added value; (2) the necessity to present additional descriptions about related-party transactions involving intangibles; and (3) the obligation to include the description of a transfer pricing policy applied by the group of related entities in the Master file.


Read an October 2017 report [PDF 390 KB] prepared by the KPMG member firm in Poland

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