Transfer Pricing Documentation for 2024 – Key Obligations and Deadlines

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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.

Deadlines

• 31 October 2025 – preparation of local file,

• 1 December 2025 – submission of TPR-C/TPR-P,

• 31 December 2025 – preparation of master file (for groups).

  
  

Legal basis:

• Art. 11k–11t of the Corporate Income Tax Act (Journal of Laws of 2025, item 278, as amended)

• Art. 23w–23zf of the Personal Income Tax Act (Journal of Laws of 2025, item 163, as amended)