The Polish Ministry of Finance published a draft regulation on 27 April 2015 which introduced amendments on transfer pricing documentation in line with the requirements of the OECD/G20 action plan on base erosion and profit shifting (BEPS).  

As per the Bill released by the Minister of Finance for public consultation, a resident entity that is part of a multinational corporate group with annual consolidated income of at least €750 million will be required to prepare a comprehensive report reflecting the activities and taxes paid in each country in which the group operates, i.e., the country-by-country reports (CbCR). A taxpayer that is part of a multinational corporate group with annual income or expenses of at least €20 million will be required to prepare and deliver a master file report containing standardized information relevant to all group members and to deliver a local file specifically related to transactions carried out by the taxpayer. A taxpayer that is part of a multinational corporate group with annual income or expenses of at least €10 million, or making payments to entities registered in low-tax jurisdictions, will be required to prepare and deliver a simplified report on transactions with associated entities. Taxpayers with annual income below €2 million will fall outside the scope of transfer pricing documentation requirements. The management or control shareholding of a taxpayer qualifying as a related party for transfer pricing purposes will be 20% (previously 5%) as per the draft bill. All these changes if enacted, will be implemented from 1 January 2016.