If you conduct transactions with related parties, now is the time to verify your transfer pricing compliance requirements. For most taxpayers, the deadlines are just around the corner. Don’t delay – safeguard your tax position by checking how much time remains to meet your obligations.
What will you learn from this article?
What are the key deadlines for transfer pricing documentation in 2025?
The local file for 2024 must be prepared by 31 October 2025, and the TPR report must be filed by 30 November 2025, provided that the tax year coincides with the calendar year.
Who is required to prepare transfer pricing documentation?
The obligation applies to related parties whose transactions exceed the thresholds: PLN 10 million for goods and financial transactions, PLN 2 million for service transactions, and PLN 0.5 million for transactions with tax havens.
What penalties may be imposed for failing to comply with transfer pricing obligations?
Failure to submit documentation or providing incorrect data in the TPR report may result in a fine of up to 720 daily rates. Additional sanctions include income reassessment and a tax of up to 30% of the understated income.
Which documents must be filed as part of transfer pricing reporting?
It is necessary to prepare the local file, submit the TPR report, and – in the case of large capital groups – prepare the master file by 31 December 2025.
How to prepare for a tax audit in the area of transfer pricing?
Gather all transaction data such as contracts and invoices, ensure that prices comply with the arm’s length principle, and consult an expert to avoid mistakes in the documentation.
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When must the transfer pricing documentation be prepared?
Taxpayers required to prepare local transfer pricing documentation (Local File) must do so by the end of the 10th month following the end of their tax year.
For taxpayers whose tax year aligns with the calendar year, the deadline is October 31, 2025.
TPR Information
Preparing the documentation is not the only transfer pricing obligation. Taxpayers must also submit the TPR form to the Tax Office by the end of the 11th month following the end of the tax year.
For entities whose tax year is the calendar year, the deadline is November 30, 2025.
Master File
The obligation to prepare group transfer pricing documentation (Master File) applies to related parties whose financial statements are consolidated using the full or proportional method and who are also required to prepare a Local File, provided they belong to a group of related entities that:
- prepares consolidated financial statements,
- generated consolidated revenue exceeding PLN 200 million (or its equivalent) in the previous financial year.
This obligation must be fulfilled by the end of the 12th month following the end of the tax year.
For taxpayers whose tax year aligns with the calendar year, the deadline is December 31, 2025.
Beware of the consequences!
Failure to comply with transfer pricing obligations may result in significant fiscal penalties imposed by tax authorities. However, that’s not the only reason to take this matter seriously.
Transfer pricing remains a key focus area for tax authorities, and the effectiveness of audits in this area continues to grow – largely due to data reported in the TPR. This information provides a powerful tool for the tax office in selecting entities for further control.
That means transfer pricing obligations should not be ignored. Preparation of documentation and submission of the TPR is not just about meeting deadlines – it’s also about minimizing risk. Entrusting this process to an experienced tax advisor is a smart move.
Our team is ready to support you in fulfilling your obligations and ensuring your documentation complies with all applicable regulations. Feel free to contact us.
