Transfer Pricing in Poland (2026): Documentation, TPR, Thresholds and Deadlines

Poland has some of the most detailed transfer pricing (TP) rules in the EU. Any transaction between related parties must be priced at arm’s length. Above set thresholds, taxpayers must prepare a local file: by 31 October 2026 for calendar-year 2025. They must also file a TPR-C (companies) or TPR-P (individuals and partnerships) information return by 30 November 2026. Large groups add a master file and country-by-country (CbC) reporting. Safe harbours exist for low value-adding services and intra-group loans. A government bill that would simplify the TPR from tax year 2026 has not yet been passed by parliament (October 2026) and does not change this year’s deadlines.

Deadline alert: for calendar-year taxpayers, the 2025 local file is due by 31 October 2026. That is a Saturday, so the safe approach is to have it ready by Friday 30 October.

This guide describes the law as of September 2026. Transfer pricing is technical and fact-specific: use it to understand your obligations, and confirm your position with a Polish tax adviser.

Key numbers

Item	Rule
Related-party threshold	25% of capital, votes or profit rights (directly or indirectly)
Local file: goods and financial transactions	Over PLN 10 million per type of transaction, per year
Local file: services and other transactions	Over PLN 2 million
Tax haven counterparties	Over PLN 2.5 million (financial) / PLN 500,000 (other)
Master file	Group consolidated revenue over PLN 200 million
Country-by-country report	Group consolidated revenue over PLN 3.25 billion (≈ EUR 750 million)
Local file deadline	End of the 10th month after year-end
TPR deadline	End of the 11th month after year-end

Who counts as a related party?

Under the Polish CIT and PIT Acts, entities are related when:

• one holds, directly or indirectly, at least 25% of the shares, voting rights or rights to profits of the other;
• the same person or entity holds such a 25% stake in both;
• one exercises significant influence over the other through management or control; or
• there are family, employment or property ties between their managers or owners.

A company and its foreign permanent establishment are also treated as related. Once parties are related, every transaction between them is a controlled transaction and must meet the arm’s-length principle, whether or not documentation is required.

When is a local file required?

Documentation thresholds apply separately to each type of controlled transaction, per tax year, net of VAT. They apply to both income and costs.

Type of controlled transaction	Local file required if the annual value exceeds
Goods (commodity) transactions	PLN 10,000,000
Financial transactions	PLN 10,000,000
Services	PLN 2,000,000
Other transactions	PLN 2,000,000
Financial transactions with a tax-haven entity	PLN 2,500,000
Other transactions with a tax-haven entity	PLN 500,000

Common exemptions include domestic transactions where both parties meet certain conditions (for example, neither has a tax loss and neither benefits from special economic zone relief), transactions covered by an advance pricing agreement, and transactions within a tax capital group.

Benchmarking: the local file must include a comparability or compliance analysis showing that the price is at arm’s length. Benchmarking studies generally need to be updated at least every three years, and financial data should be refreshed annually.

Master file and CbC reporting

• Master file: required if the taxpayer belongs to a group that prepares consolidated financial statements and the group’s consolidated revenue exceeded PLN 200 million in the previous year. The Polish entity must have it by the end of the 12th month after year-end.
• Country-by-country report (CbC-R): required for groups with consolidated revenue above PLN 3.25 billion (about EUR 750 million). It is filed within 12 months of year-end by the Polish entity responsible, usually the ultimate parent or a designated surrogate.
• CbC notification (CbC-P): every Polish member of such a group must notify the tax authority of which entity will file the CbC report, and where, by the end of the 3rd month after year-end.

TPR: the transfer pricing information return

The TPR is a structured electronic return, filed via e-Deklaracje, that reports each controlled transaction, the pricing method and, where relevant, benchmarking results.

• Who files: related entities that are required to prepare a local file, and also entities whose transactions are exempt from documentation in certain cases (for example, safe-harbour transactions).
• Forms: TPR-C for corporate income tax, TPR-P for personal income tax. Updated electronic versions, TPR-C(6) and TPR-P(6), apply to tax years beginning after 31 December 2024.
• Deadline: the end of the 11th month after year-end. For 2025 calendar-year taxpayers, that is 30 November 2026.
• Statement: under current law, the TPR includes a statement confirming that the local file has been prepared and that transfer prices are at arm’s length.

Deadlines for tax year 2025 (calendar-year taxpayers)

Obligation	Deadline
CbC notification	31 March 2026
Local file (incl. benchmarking)	31 October 2026
TPR-C / TPR-P, incl. statement	30 November 2026
Master file	31 December 2026
CbC report	31 December 2026

Note: 31 October 2026 falls on a Saturday. Whether a deadline for preparing an internal document moves to the next working day is not clearly settled, so the safe approach is to finish the local file by Friday 30 October 2026. Once prepared, it must be handed over within 7 days of a request from the tax authority.

Safe harbours

Poland offers two simplified regimes. If all conditions are met, the price is presumed to be at arm’s length, and no local file or benchmarking is needed. The transaction must still be reported in the TPR.

Safe harbour	Main conditions
Low value-adding services (e.g. accounting, IT support, HR)	Markup of no more than 5% of costs for the buyer, or at least 5% for the provider, calculated on a cost basis in line with the statutory list of services and conditions
Loans, credits and bonds	Interest based on an official base rate (for PLN: WIBOR 3M, WIRON 3M or, from 2026, POLSTR 3M) plus a margin of at most 2.6 pp for the borrower or at least 2.0 pp for the lender (Ministry of Finance announcement, December 2025), with further conditions on term, fees and counterparties

Penalties

• Additional tax liability: when the tax authority adjusts income under TP rules, it also imposes an additional liability of 10% of the adjustment. The rate rises to 20%, or 30% in the most serious cases, for example when documentation was not provided or the adjustment is very large. The authority may waive it if the taxpayer acted in good faith.
• Fiscal penal liability: responsible individuals, typically board members, can face fines of up to 720 daily rates under the Fiscal Penal Code for failing to prepare documentation, or for filing a TPR that is missing or untrue. Lower fines apply to late filings.

APAs and dispute resolution

• Advance pricing agreements (APA): unilateral, bilateral or multilateral agreements with the Head of the National Revenue Administration (KAS) that confirm the pricing method for future transactions, typically for up to five years.
• MAP and arbitration: double taxation caused by TP adjustments can be resolved through the Mutual Agreement Procedure under tax treaties or the EU Arbitration Convention and Directive.

Planned changes: the 2026 deregulation bill

In March 2026 the government published a draft amendment to the CIT and PIT Acts (project UDER107) as part of its deregulation programme. After consultation it was revised in June, and the Council of Ministers adopted the bill in July 2026. As adopted, it would:

• remove the separate arm’s-length statement entirely, rather than moving it from the TPR into the local file as the March draft proposed;
• allow the TPR to be signed by a proxy under general tax procedure rules;
• exempt micro and small enterprises from reporting financial indicators in the TPR;
• clarify the rules on transfer pricing adjustments, including between Polish related parties;
• drop the Fiscal Penal Code changes included in the March draft;
• from 1 January 2027, end the rule that disallows tax-deductible costs for payments to bank accounts not on the VAT whitelist (or made without split payment). VAT-related sanctions would remain.

Timing: the TPR simplifications would apply to TPR returns for tax years starting after 31 December 2025, so for calendar-year taxpayers, from the TPR for 2026, filed in 2027. Obligations for tax year 2025 are unchanged.

Status (October 2026): adopted by the government but not yet passed by parliament or published in the Journal of Laws, so the current rules apply in full. We will update this guide when the act is passed.

Practical checklist for foreign groups in Poland

1. Map all related parties and intra-group flows early in the year: goods, services, royalties, loans, cash pooling and guarantees.
2. Test each type of transaction against the thresholds to decide which need a local file.
3. Check safe-harbour eligibility for intra-group loans and low-value services before signing agreements.
4. Refresh benchmarks: at least every three years, with annual financial updates.
5. Plan for October: the local file is due before the TPR, and in 2026 the deadline falls on a weekend.
6. Confirm who signs the TPR and the statement, and make sure board members understand their personal liability.

Setting up operations in Poland? Start with our Poland market entry guide, learn how to verify a Polish company in the official registers, and see our overview of financing a business in Poland.

Sources

• Ministry of Finance, Transfer pricing (podatki.gov.pl) and TPR information.
• Corporate Income Tax Act, Articles 11a–11t (transfer pricing), and Tax Ordinance, Articles 58a–58c (additional tax liability).
• Grant Thornton Poland, Transfer pricing deregulation 2026 (January 2026) and Amendment of the TPR regulations (January 2026).
• Instytut Cen Transferowych, Government adopts bill simplifying TPR obligations and limiting tax sanctions and PIT.pl, Government adopts measures to simplify tax obligations (23 July 2026).
• Deloitte Poland, Transfer pricing changes 2026: how the post-consultation draft differs (July 2026).
• ICT, Update of safe harbour conditions for financial transactions in 2026.