Poland’s Updated Transfer Pricing Reporting Regulations Take Effect

October 3, 20230

In a pivotal development for tax professionals, investors, and businesses in Poland, the Minister of Finance has implemented amendments to the decrees governing transfer pricing reporting related to corporate income tax and individual (personal) income tax. These revisions, which were initially announced on December 5, 2022, became effective on September 16, 2023, with the primary aim of aligning the regulations with recent legislative changes. 


Repealing Indirect Haven Transaction Disclosure: 

One of the primary objectives of these amendments is the removal of the provision pertaining to the disclosure of information on so-called “indirect haven transactions.” This significant change streamlines reporting requirements and simplifies the compliance process for taxpayers. It represents a crucial step in reducing administrative burdens associated with transfer pricing reporting. 


Eliminating Share of Costs Indicator: 

Additionally, the decrees have eliminated the requirement for the indicator of the share of costs of operating activities with related entities in the operating costs of the entity. This adjustment recognizes that the previous indicator could be complex and potentially confusing for taxpayers. By removing this element, the regulatory framework becomes more straightforward and easier to navigate. 


Effective Timeline: 

These amendments are applicable to transfer pricing reports for tax years commencing after December 31, 2021. It’s essential for tax professionals, investors, and businesses to understand the implications of these changes for their financial planning and compliance efforts. Staying informed and up-to-date is crucial to ensure seamless adherence to the revised regulations. 


In conclusion, the effective implementation of these amendments to Poland’s transfer pricing reporting decrees marks a significant milestone in the country’s tax landscape. With a focus on simplification and alignment with legislative changes, these revisions are poised to benefit taxpayers and facilitate smoother compliance. 


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