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 2026

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

The event comes at an important moment for professionals dealing with practical realities related to this practice area
Germany’s dogmatic restriction of third-party investment in tax advisory firms will only serve to slow down innovation and access to justice
The Irish government has been told that it’s spending too much of its corporation tax receipts and should instead focus on running bigger surpluses; plus, the IRS is set to merge tax practitioner offices
A company risks double taxation, penalties and inquiry cost if it submits a form with anomalies under the new system, Asker Ali also tells ITR
Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies
The scandal has come just three years after the PwC tax leaks controversy and has prompted KPMG’s Australian chief executive to resign
In the first of a two-part series on capital v revenue in R&D, Jayne Stokes explores these key concepts and where UK companies need to tread carefully
Magnus Pantzar is set to join as managing director after spending nearly a decade as EQT’s global head of tax
The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals
The recent spree of firm mergers and acquisitions proves that geographic scale is the name of the game
Gift this article