Transfer Pricing
Country Summary

This document outlines Poland’s transfer pricing regulations, emphasizing that they are well-established and align with OECD Guidelines. It covers aspects like statutory documentation requirements, the definition of related parties, tax havens, and advanced pricing agreements (APAs). The document highlights new rules related to tax havens and provides insights into transfer pricing adjustment mechanisms.


Poland’s transfer pricing regulations are firmly in place and in line with OECD Guidelines. They pertain to both domestic and cross-border transactions and have been in effect since 2001.

Legal Framework and Definitions:

While these regulations draw inspiration from OECD Guidelines, they aren’t formally acknowledged as primary law. Article 11 of the Corporate Income Tax Act forms the basis for applying the arm’s length principle. Key definitions and documentation requirements are outlined in Article 9a of the CIT.

Defining Related Parties:

Poland introduces a comprehensive definition of related parties. Related entities are those with a 25% share capital connection, including family-related entities. Relationships formed for non-legitimate economic reasons are also scrutinized.

Transfer Pricing Documentation:

Poland mandates certain taxpayers to prepare an “Executed tax strategy” report, including transfer pricing information. Exemptions apply to specific entities, and new transfer pricing adjustment mechanisms are introduced.

Tax Havens and APAs:

Poland has enacted rules targeting transactions with companies in tax havens. APAs have been in use since 2006, providing protection against audits.

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