Transfer Pricing
If your company enters into transactions with related parties – a subsidiary, a parent company, a partner or another structure within the same capital group, especially if it operates abroad – transfer pricing rules may impose specific documentation obligations on you. Ignoring them is one of the more common mistakes when building international structures, and the consequences can be severe: an additional tax liability, a 10% penalty on the challenged amount and liability under the Fiscal Penal Code.
What is transfer pricing?
It is the principle under which transactions between related parties must be concluded on market terms – the terms that independent entities would agree between themselves (the arm's length principle). It applies to the sale of goods, the provision of services, the granting of loans or the licensing of trademarks within a group.
What are the current documentation thresholds (2026)?
The obligation to prepare local documentation (the Local File) arises when the value of a homogeneous transaction in a given tax year exceeds: PLN 10 million for goods and financial transactions and PLN 2 million for service and other transactions. For transactions with entities from tax havens the thresholds are considerably lower – PLN 2.5 million for financial transactions and PLN 500,000 for the others, regardless of whether the other party is formally a related party.
What are the deadlines in 2026?
For taxpayers whose tax year coincides with the calendar year, the following deadlines apply to settlements for 2025: Local File by 2 November 2026, TPR information by 30 November 2026, and the group documentation Master File by 31 December 2026.
What can our help include?
- Analysis of the transaction structure within the capital group and determining whether a documentation obligation arises.
- Preparation of the Local File and, if needed, the Master File.
- Comparative analysis (benchmarking) showing the arm's length nature of transactions.
- Verification of whether the safe harbour can be applied – a simplified settlement available, among others, for intra-group loans and low value-added services.
- Preparation and filing of the TPR information on time.
- Representation in an audit, including help with a voluntary correction of returns before an audit begins, which allows sanctions to be avoided.
Result: documentation prepared in line with current rules and the 2026 deadlines, intra-group transactions protected against the allegation of non-arm's length settlements, and certainty that the international structure does not generate hidden tax risk.
