Transfer Pricing Documentation for 2024 – Key Obligations and Deadlines

Paweł Gorzelec
Nov 6
1 min read

As the year comes to an end, many taxpayers face additional reporting and documentation duties – including the preparation of transfer pricing documentation for 2024. Who is obliged, what thresholds apply, and by when must the documentation be completed? Here’s a concise overview.

Who is required to prepare transfer pricing documentation?

Taxpayers engaging in controlled transactions with related parties exceeding the following annual thresholds:

PLN 10,000,000 – goods transactions,
PLN 10,000,000 – financial transactions,
PLN 2,000,000 – service transactions,
PLN 2,000,000 – other transactions.

Transactions with entities located in tax havens may also trigger documentation requirements:

PLN 2,500,000 – financial,
PLN 500,000 – other.

Exemptions

For domestic transactions between Polish entities, documentation is not required if all of the following are met:

neither party benefits from income tax exemptions,
neither party benefits from SEZ or support decision exemptions,
neither party incurred a tax loss.

TPR Information

Taxpayers must file the TPR report (TPR-C for CIT / TPR-P for PIT) electronically to the tax office. It includes information about related entities, controlled transactions, methods used, and a statement that prices are at arm’s length.