Transfer Pricing Reports

Transfer Pricing Report is a document presented at the request of tax authority, which allows for the verification of the market nature of the price applied in the transaction concluded with a related party or an entity with its residence, management board or registered office in the so-called "tax haven". The obligation to prepare the TP report stems directly from the provisions of the PIT Act and the CIT Act, which specify who and when is obliged to prepare it, what is its scope, and what elements it shall include.

Until 31 December 2016, related entities were required to prepare the TP report at a local level, the so-called local file (applicable regulations failed to specify the time limit in which it should be prepared). Since 1 January 2016, for few entities, an additional obligation to prepare reporting by country has been introduced, the so-called Country-by-Country Reporting.

Starting from 1 January 2017, the scope of the TP report has been significantly expanded and it has been made dependent on the level of accounting revenue or expenses of the taxpayer.