Poland: Poland prepares for new TP-R reporting

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Poland: Poland prepares for new TP-R reporting

Sponsored by

sponsored-firms-mddp.png
The forms hope to increase efficiency

Magdalena Marciniak and Magdalena Dymkowska of MDDP outline how the new TP-R form will make positive changes to the art of tax reporting in Poland.

Polish taxpayers will have until the end of September 2020 to file a new declaration – the TP-R form - related to FY 2019, with the tax authorities. Taxpayers may expect the new obligation to bring more radical changes than expected in some areas.

TP-R is a tax information form to be filed electronically with the Head of National Revenue Administration. Given the extent of the detailed data and information to be reported, it will be an ideal tool to identify transactions to be later verified during a tax audit.




The TP-R form must disclose:

  • general financial information (including values of financial ratios measuring a taxpayer’s financial position); 

  • information about related entities and controlled transactions;

  • information about transfer pricing method used to verify the arm’s length character of the controlled transactions;

  • the result of the comparability analysis.


Given that the comparability analysis is a mandatory element of a local file since 2019, the presentation of the result of analysis and reference to the actual transfer price (e.g. profitability ratio) should be also reported in TP-R. Also, TP-R must present profitability ratio when the filing taxpayer is a service recipient. In practice, calculation of profitability ratio could be challenging and time-consuming for each organisation, particularly in cases featuring a foreign service provider. Therefore, it is necessary that entities acquiring services from related parties cooperate with the service provider to possess all information required under the new rules. 




Additionally, taxpayers will be obliged to provide very specialised and detailed information related to benchmarking studies such as the tested party and the region analysed. Also information regarding the adjustments applied in the benchmarking process will be required. Therefore, completing the form may be demanding and it will require delving into the benchmarking process or using support of external advisors.



In the light of the above, reporting obligations in TP-R will impose on Polish taxpayers more administrative effort compared to the CIT-TP / PIT-TP form, which taxpayers submitted in 2017 and 2018. 



It should be noted that failure to prepare the TP-R form, submitting a false declaration or submitting it after the deadline exposes the taxpayer to severe penal fiscal sanctions: potentially up to PLN 20 million. It is therefore necessary to take due care in correctly fulfilling all TP-R reporting obligations.



The new reporting obligation deadline will coincide with that for filing the statements on preparing local transfer pricing documentation: by the end of the ninth month after the end of the financial year. There is not much time until the end of September 2020 to collect all information required in TP-R. That is why it is advised to prepare a draft TP-R form at the beginning of 2020 in order to analyse if (i) a taxpayer knows how to fill it in, (ii) its systems support collecting required data and (iii) the remuneration applied in the intragroup transactions enables the parties to achieve the actual profitability ratio within the arm’s length range.





Magdalena Marciniak

E: magdalena.marciniak@mddp.pl



Magdalena Dymkowska

E: magdalena.dymkowska@mddp.pl

more across site & shared bottom lb ros

More from across our site

In the age of borderless commerce, money flows faster than regulation. While digital platforms cross oceans in milliseconds, tax authorities often lag. Indonesia has decided it can wait no longer
The tariffs are disrupting global supply chains and creating a lot of uncertainty, tax expert Miguel Medeiros told ITR’s European Transfer Pricing Forum
Corporate counsel should combine deep technical knowledge with strategic dynamism, says Agarwal, winner of ITR’s EMEA In-house Indirect Tax Leader of the Year award
Luxembourg’s reform agenda continues at pace in 2025, with targeted measures for start-ups and alternative investment funds
Veteran Elizabeth Arrendale will lead the new advisory practice, which will support clients with M&A tax structuring, post-deal integration, and more
MAP cases keep increasing, and cases closed aren’t keeping pace with the number started, the OECD’s Sriram Govind also told an ITR summit
Nobody likes paperwork or paying money, but the assertion that legal accreditation doesn’t offer value to firms and clients alike is false
Ryan hopes the buyout will help it expand into Asia and the Middle East; in other news, three German finance ministers have called for a suspension of pillar two
SKAT, which was represented by Pinsent Masons, had accused Sanjay Shah and other defendants of fraudulent dividend tax refund claims
TP managers must be able to explain technical issues in simple terms, ITR’s European Transfer Pricing Forum heard
Gift this article