Poland’s MoF updated the TPR Guide on 31 October 2025, revising 2024 transfer pricing currency conversion rules. The update aims to simplify reporting and improve data consistency for entities required to submit TPR.
Poland’s Ministry of Finance (MoF) published updated FAQs in the sixth edition of the TPR Guide – Questions and Answers on 31 October 2025, providing clarification on 2024 transfer pricing reporting obligations. The updates address revised procedures for converting foreign currency amounts in transfer pricing information (TPR).
The changes amend answers to questions 131 and 140 in the TPR Guide 2024, revising the method for converting amounts in the fields “Debt value”, “Amount of interest (accrual basis)”, and “Amount of interest (cash basis)”.
New questions 137 and 153 have also been added, addressing currency conversion for financial transactions denominated in foreign currencies under category group C (codes 1201–1204 and 2201–2204) and category group D (codes 1201 and 2201).
The update aims to simplify reporting and improve data consistency for entities required to submit TPR.
Taxpayers submitting transfer pricing information for the 2024 tax year may apply the updated conversion rules set out in either the fifth or sixth edition of the TPR Guide. The detailed scope of transfer pricing information continues to be governed by the Minister of Finance regulations of 29 August 2022 on transfer pricing information for corporate income tax purposes (Journal of Laws of 2025, item 459) and for personal income tax purposes (Journal of Laws of 2025, item 454).
The deadline for submitting transfer pricing information for the 2024 tax year is 11 months after the end of the tax year. For taxpayers whose tax year aligns with the calendar year, the filing deadline was 30 November 2025.
The Ministry reiterated that the TPR Guide does not constitute a general interpretation of tax law or official tax explanations under the Tax Ordinance, and that the classification of transactions requires an individual assessment based on the specific facts of each case.
