Poland’s Ministry of Finance released the fifth edition of the transfer pricing reporting Q&A (TPR Guide 2023) on 4 September 2024, offering an updated collection of answers to frequently asked questions about transfer pricing reporting obligations.

The TPR Guide 2023 provides practical examples to simplify the process of reporting information on transfer prices and ensure data consistency. The guide also provides practical examples presenting the recommended way to fill out information on transfer prices.

The guide has new questions or examples in the following parts:

General issues:

  • 21 regarding the correction of TPR Information submitted on the TPR-C (5) form;
  • 22 regarding the possibility of submitting TPR Information after the dissolution of the company during the tax year;
  • 23 regarding the submission of TPR Information in the event of the takeover of a Polish entity by a foreign entity without closing the books of account;
  • 24 regarding the submission of TPR Information by the acquiring company in the event of the acquisition of more than one company;

Section A – place and purpose of submission:

  • 26 regarding the selection of the type of TPR form by a public company;
  • 28 regarding the submission of TPR Information in option five for the acquired entity when the merger took place with the closing of the accounting books;

Section C – additional data of the entity concerned:

  • 41 referring to criteria to be adopted to determine whether an entity is a micro or small entity for the purposes of Section C of the TPR Information;
  • 42 regarding documents and information needed to calculate the indicators of section C of TPR Information by natural persons not conducting business activity;
  • 43 regarding the possibility of exercising the right indicated in the CIT Act regarding the exemption from the obligation to prepare comparative analysis;

Section D – transaction data:

  • 60 regarding fields The value of transactions per country and Transaction Value and the relationship between them;
  • 61 regarding the selection in the TPR Form of transactions in categories B and D benefiting from the simplification of safe harbour;

Section F – Statement:

  • 160 – in terms of the need to always select a statement in the TPR Information.

The deadline for submitting 2023 transfer pricing information is 11 months after the tax year ends. Taxpayers in a calendar year have a deadline of 30 November 2024.