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Are you part of a capital group and conducting business in multiple countries, including Poland? Are you planning to expand your business into Polish market? Are you wondering how to meet transfer pricing requirements?
Our expert team is here to streamline a process of transfer pricing compliance. As a comprehensive tax advisor, we can offer extensive services in the area of transfer pricing (Local file and Master file documentation, Transfer Pricing Analysis, TPR-C reporting and CBC reporting etc.).
Transfer pricing documentation is a legally required document focused on intra-group transactions. Taxpayer is required to prepare the Local File when conducting transactions with related entities and / or entities in territories / countries that engages in harmful tax competition (tax havens) or foreign establishments located in such jurisdictions.
Key Compliance Deadlines & Requirements
📌 Deadline: In Poland, the statutory deadline for preparing the Local File is the end of the 10th month following the end of the tax year.
📌 Language: Polish version is required.
📌 General rules:
The Local File, along with a benchmarking study, must be prepared for each transaction conducted with related entities exceeding the following annual thresholds:
For transactions involving entities in tax havens or foreign establishments located in such jurisdictions, the documentation threshold is:
Thresholds are determined separately for each transaction of a homogeneous nature and separately for the cost and revenue sides.
The Polish regulations also indicate a number of cases where the taxpayer is exempted from the obligation to prepare a Local File.
We offer extensive expertise in preparing tailor-made transfer pricing documentation for all types of intercompany transactions, business restructurings, and other significant corporate events.
Our transfer pricing documentation ensures full compliance with:
✅ Polish TP regulations (both current and previous, covering all audit-relevant years)
✅ OECD TP Guidelines, including the BEPS Action 13 format
Expertise and Experience: With a team of over 40 highly qualified experts, we offer deep industry knowledge and diversified skills. The high quality of our work is recognized by numerous awards and distinctions, confirming our reputation as a trusted advisor.
Comprehensive Support: While preparing Local File documentation, we proactively identify potential risks and bring them to your attention. If your needs extend beyond TP Compliance, we also provide strategic transfer pricing advisory to ensure holistic support.
Tailor-Made Solutions: We take a comprehensive and customized approach, leveraging the expertise of other CRIDO teams and our industry-specific experience to deliver solutions perfectly aligned with your business needs.
Involvement of Partners & Managers: Our partners and managers, each with many years of experience, are directly engaged in every phase of the project. This ensures top-tier quality, efficiency, and a strategic approach to achieving your goals.
Proactive Updates & Regulatory Insights: Through active participation in legislative processes, we stay ahead of regulatory changes, ensuring that your business is always compliant and well-prepared for evolving tax and transfer pricing requirements.
Contact us today to learn more about how we can assist you to achieve your business goals involving Poland in a safe way.
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