Poland: new transfer pricing explanations

July 30, 2019 Poland

The Polish Ministry of Finance shows considerable activity in the field of tax explanatory publications in various areas of tax law. The explanations in the area of ​​transfer pricing concerning the preparation of comparative analyzes and descriptions of compliance about the provisions in force until the end of 2018, have been published recently.

The recommendations are the result of work within the Transfer Pricing Forum (cooperation platform between taxpayers and the Ministry of Finance). The publication of new explanations should be assessed positively since the preparation of comparative analyzes for many taxpayers is still difficult.
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The Ministry of Finance did not omit in its recent publications taxpayers who decided to meet their transfer pricing obligations for the tax year starting after December 31, 2017, in accordance with the new TP regulations (which came into force from 2019).

On July 17, 2019, explanations regarding the obligation to submit a statement on the preparation of local transfer pricing documentation based on the regulations in force since 2019 appeared on the Ministry's website. It was pointed out that the statement:

  • must be submitted in electronic form,
  • signs the head of the unit within the meaning of the Accounting Act,
  • includes a statement of the unit's manager that the prices in transactions subject to the documentary obligation have been set on terms that would be agreed between unrelated entities.

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Photo: Beatriz Perez Moya