Poland: Proposed changes to transfer pricing rules | KPMG Global
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Poland: Proposed changes to transfer pricing rules

Poland: Proposed changes to transfer pricing rules

The Ministry of Finance on 16 July 2018 published a draft bill that would amend, among other tax measures, the transfer pricing rules.


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The draft legislation (Polish) would provide a new, separate chapter dedicated to transfer pricing in both the corporate income tax and individual income tax laws. The new measures are proposed to be effective from 1 January 2019.

Among the proposals are measures for the:

  • Reduction of documentation obligations
  • Extension of deadlines for transfer pricing information (to nine months, from three months, after the tax year-end) and a 12-month extension from the tax year-end for preparing the Master file
  • Use of Master file documentation prepared by another entity from the group and use of the Master file if prepared in English (but the tax authorities may request a Polish version be submitted within 30 days) 
  • Unification of the Polish rules with OECD standards and guidelines
  • Introduction of simplified settlements rules (safe harbours for transactions related to loans and low value-added services)
  • Extension of the types of transfer pricing methods other than the five basic methods allowed currently under Polish law
  • Rules for determining the timing of transfer pricing adjustments
  • Ability of the tax authorities to use administrative discretion in determining the taxpayer's income or loss
  • Transfer pricing reporting in electronic form
  • Clarification of certain terms and definitions


Read a July 2018 report [PDF 503 KB] prepared by the KPMG member firm in Poland

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