On 28 June 2021, Poland Ministry of Finance issued a plans for taxpayer-friendly amendments to the transfer pricing regulations. The following measures have been proposed under this plan.
- Cancellation on the preparation of transfer pricing documentation and the arm’s length nature of the applied transfer prices as a separate document rather to merge each other into the transfer pricing information return (TPR) so that only one form is required.
- Removal of the obligation to conduct a comparability analysis for controlled transactions entered into by micro and small taxpayers and for transactions, other than controlled, concluded with a tax haven entity.
- Extending the deadline for the submission of local transfer pricing documentation by the taxpayer to 14 days at the request of the tax authority.
- Extension of the deadline for the preparation of local transfer pricing documentation until the end of the tenth month after the end of the entity’s tax year. In turn, the deadline for submitting information on transfer pricing was extended to the end of the eleventh month after the end of the entity’s fiscal year.
- Exemption from the obligation to prepare local documentation for safe harbor transactions regarding loans, credits and bonds.
- Exemption from the documentation obligation for the so-called clean re-invoicing.
