On 21 October 2022, the President of Poland signed the Law of 7 October 2022 amending the Corporate Income Tax Act (referred to as Polish Deal 3.0), including certain transfer pricing changes. One of the most significant changes to transfer pricing is the elimination of TP documentation requirement for indirect tax haven transactions which was introduced in 2021. In addition, the thresholds for direct haven transactions have been raised to PLN 2,500,000 for a financial transaction; PLN 500,000 – for a transaction other than a financial transaction. Previously obliging documentation threshold for direct tax haven transactions was PLN 100 000, regardless of the type of transaction. The new provision will enter into force from 1 January 2023.
