The President of Republic of Poland signed an Act amending the Corporate Income Tax (CIT) Act, the Personal Income Tax (PIT) Act on 27 October 2015. The Act initiated important changes related to transfer pricing (TP) documentation. As per the amended Corporate Income Tax (CIT) Act, tax authorities may request documentation concerning transactions or events if it is probable that the value of the transaction was intentionally reduced to avoid the documentation requirement and the time for submitting this documentation would be 30 days from the date of the request not the standard deadline of seven days and it will be effective from 1 January 2017. As per the amended tax Act, 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. Poland has introduced a requirement for a master file and local file and master file will be mandatory to provide information for taxpayers with turnover of above €20 million. Master file will contain information regarding description of the group’s capital structure, TP policy and significant intangible assets utilized but a local file will contain specific TP information for each relevant country of operation.

Poland has introduced CbC reporting and the country by country reporting requirement applies where the consolidated group revenue in the preceding year exceeded EUR 750 million. The CbC report must be submitted within twelve months after the end of the tax year.