TP OBLIGATIONS

TP obligations

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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Determining TP obligations

Identifying transactions subject to transfer pricing (TP) compliance obligations in Poland is crucial for ensuring tax efficiency while reducing exposure to sanctions under Polish tax law. Many businesses struggle with determining which transactions require documentation, whether they exceed reporting thresholds, and how to classify them correctly.

Moreover, a critical aspect of TP compliance is verifying when a benchmarking analysis is required, as its results are reported in TPR-C forms. These TPR-C forms, submitted to tax authorities, play a key role in selecting taxpayers for audits, making proper TP compliance essential for risk management.

How can we help?

Our support may include the identification of the related parties and transactions which are subject to transfer pricing obligations. This includes identifying:

• entities classified as related parties in the meaning of Polish TP regulations,
• which transactions exceed documentation thresholds, by considering their homogeneous nature,
• which can benefit from the local exemptions,
• which require a transfer pricing analysis, and
• which need to be presented in the TPR-C form.

We assist clients in identifying non-obvious transactions — economic events that, based on current regulations, our expertise, or prevailing interpretative practices, may be classified as transactions subject to transfer pricing documentation requirements but sometimes escape taxpayers’ attention.

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: We go beyond simple transaction identification — our approach ensures correct classification, grouping, and risk assessment. We proactively highlight transactions that may not be obvious to taxpayers but require documentation under Polish TP rules.

  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.