New Transfer Pricing Requirements In Poland

The amendment of Poland’s CIT act includes substantial changes to required transfer pricing documentation for taxpayers.

Recent amendments to Poland’s Corporate Income Tax act includes substantial changes to taxpayer’s required transfer pricing documentation. The new rules are in effect from 1 January 2017 - however CBC reporting obligation starts from 2016.

The related entities threshold will rise from a shareholding of 5% to a shareholding of 25%. The transfer pricing requirements will be determined based on the taxpayer’s business size.

• If in a preceding tax year the taxpayer’s total annual cost or revenue did not exceed €2m there will be no obligation for transfer pricing documentation for transactions with related parties.