Poland's Council of Ministers approved amendments to the income tax law that eliminate penalties for off-list contractor payments and streamline transfer pricing disclosures for related-party transactions, with changes rolling out from summer 2026 through January 2027.
The Polish Council of Ministers approved amendments to the Personal Income Tax Act and Corporate Income Tax Act on 21 July 2026, designed to cut red tape around transfer pricing disclosures and reduce penalties for misfiled payments.
The changes flow from the government’s broader deregulation agenda and take effect in stages through 2027.
Penalties scrapped for off-list payments
Companies will no longer face sanctions or lose expense deductions if they pay contractors outside the VAT whitelist or circumvent the split payment mechanism. Previously, using an account not on the tax authority’s registered VAT payer list could trigger costly penalties, even when the underlying transaction was legitimate.
Transfer pricing forms get simpler
The TPR form—which reports settlements between related entities—no longer requires a board member or certified professional to sign it. Any authorised company representative can now sign under the same rules as standard tax returns, cutting friction in the approval process.
Micro and small entrepreneurs will no longer be required to provide indicators describing the company’s financial situation in their TPR reports. This will make document preparation simpler and less time-consuming.
Timeline
The amendments take effect 14 days after publication in the Journal of Laws.
Transfer pricing simplifications apply to reports filed for the 2026 tax year.
The penalty changes take effect on 1 January 2027.
