MASTER FILE

Master file

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.).

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Master file

Master File documentation primarily applies to capital groups and includes information about the entire group of related entities. However, the Master File is not required for every capital group, but only for those that meet specific criteria.

Key Compliance Deadlines & Requirements

📌 Deadline: The Master File must be prepared by the end of the 12th month following the end of the tax year.

📌 Language: An English version is permitted, but a Polish version must be submitted upon request by tax authorities within 30 days.

📌 General rules:

Entities consolidated using the full or proportional method that are required to prepare a Local File must also supplement it with a Master File, provided they belong to a group of related entities that:

• prepare a consolidated financial statement, and
• exceed PLN 200M (approx. EUR 48M) in consolidated revenues in the previous financial year.

The Master File can be prepared by:

• a related entity required to prepare group transfer pricing documentation, or
• another entity within the group.

However, delegating the preparation of the Master File to another group entity does not exempt Polish entities from compliance with local transfer pricing requirements.

How can we help?

Crido’s support may include:

✅ comprehensive preparation of the Master File from scratch, or

✅ verification of group transfer pricing documentation (Master File) to ensure compliance with formal requirements, supplemented with relevant tax year information, along with consultations on risks related to intra-group transactions.

Why choose CRIDO?

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 Master File documentation, we proactively identify potential risks associated with intra-group transactions 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.