The Governmental anti-COVID-19 regulations under ‘Tax Shield 4.0 project’ are currently being voted in Polish Parliament. They will bring much anticipated ease for the Polish taxpayer also with respect to transfer pricing compliance obligations.

According to the voted regulations, the deadline for submitting transfer pricing information (TPR-C and TPR-P forms) as well as the statement on preparation of local transfer pricing documentation for FY2019 is extended from the end of September 2020 till the end of December 2020, i.e. by three months.

Certainly, in these "extraordinary" circumstances of COVID-19, the additional time to comply with transfer pricing obligations will be very helpful. Merely meeting the reporting obligations in the form of a TPR form is quite a challenge. In addition, a statement on the preparation of the local documentation under severe penalties of fiscal penal sanctions imposes an obligation to confirm that the intercompany transactions follow the arm’s length principle, hence the additional three months will allow better preparation for the new reporting challenges.

The draft regulation also extends the deadline for preparing the Master file documentation by three months.

We will keep you informed about the further development of this draft (at the time of publication of this entry, the draft was after the second parliamentary reading).