Accounting & tax services Transfer pricing
Transfer pricing services
and documentation in Poland
We assess transfer pricing obligations for related-party transactions and prepare Local Files, Master Files, benchmarking studies and Polish TPR information returns. We also support companies with transfer pricing adjustments, business restructurings and tax audits.
Related-party transactions require
a consistent approach.
Transfer pricing rules govern the terms applied to transactions between related parties. Those terms should reflect what independent parties would have agreed in comparable circumstances, in line with the arm’s length principle.
Compliance is not limited to preparing documentation after year-end. It also requires identifying related parties and controlled transactions, reviewing thresholds and exemptions, selecting an appropriate method, preparing benchmarking studies and ensuring consistency between agreements, accounting records, transfer pricing documentation and the TPR return.
We help organise the full process — from assessing obligations and transaction terms to preparing documentation and supporting adjustments or tax audits. The applicable requirements are determined separately for each transaction, taking account of its type, value, parties, tax year and available exemptions.
- Local File
- Polish local transfer pricing documentation
- Benchmark
- benchmarking study or compliance analysis
- Master File
- group transfer pricing documentation, where required
- TPR
- preparation of the Polish transfer pricing information return
01 Obligation
Does your company have
transfer pricing obligations in Poland?
Entering into a transaction with a related party does not automatically trigger a Local File requirement. The obligation is assessed separately for each homogeneous controlled transaction, taking account of its type, value, parties, tax year and any available exemptions.
We review capital, personal and family links as well as other forms of effective influence. We then identify transactions and relevant events, assess how they should be grouped, test their values against the documentation thresholds, review exemptions and consider special rules for dealings with entities in jurisdictions applying harmful tax competition.
The result is a clear obligation map showing which transactions require a Local File, benchmarking study or compliance analysis, Master File, TPR return or Country-by-Country reporting, together with the applicable deadlines.
02 Thresholds
What are the transfer
pricing documentation thresholds in Poland?
A Local File is required for a homogeneous controlled transaction when its value in the tax year exceeds the relevant documentation threshold. Thresholds are tested separately for the cost and revenue sides, regardless of the number of invoices, payments or related parties involved.
Lower thresholds may apply to transactions with entities or foreign permanent establishments located in jurisdictions applying harmful tax competition: PLN 2.5 million for financial transactions and PLN 500,000 for other transactions.
- PLN 10 million
- Goods and financial transactions.
- PLN 2 million
- Service transactions and other transactions.
03 Sanctions
Liability for transfer pricing
documentation and TPR filings.
Failure to meet Polish transfer pricing obligations may lead to fiscal penal liability. This may include failing to prepare a Local File, failing to attach a required Master File, preparing documentation late or preparing it inconsistently with the facts.
Separate liability may arise where a TPR return is not filed, is filed late or contains information inconsistent with the documentation or the actual transaction. Because TPR also includes a statement regarding the documentation and the arm’s length nature of prices, the data, agreements, accounting records, analyses and documentation should be checked for consistency before signing.
The scope of personal liability depends on the individual’s role and the facts of the particular case.
04 Offer
Comprehensive transfer pricing support.
- Review of related-party links, controlled transactions, thresholds, exemptions and documentation obligations.
- Preparation of a Local File or adaptation of existing documentation to Polish requirements.
- Benchmarking studies and compliance analyses, including selection of the appropriate transfer pricing method.
- Preparation, review and adaptation of a Master File to Polish requirements.
- Preparation of TPR-C or TPR-P information and reconciliation with documentation and accounting records.
- Development and updating of transfer pricing policies, calculation rules, mark-ups, allocation keys and internal procedures.
- Support with transfer pricing adjustments, business restructurings, tax-haven transactions and safe-harbour simplifications.
- CbC-R and CbC-P reporting and support during tax audits.
05 Process
How we deliver transfer pricing projects.
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01
Group data and structure
We collect information on the group structure, related parties, agreements, settlements and transactions.
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02
Obligation assessment
We identify controlled transactions, review thresholds and exemptions, and agree the scope and timetable.
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03
Analysis and documentation
We perform the functional analysis, select the pricing method and prepare the Local File, Master File and required studies.
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04
Review and TPR
We reconcile the documentation with agreements, accounting records and the actual conduct of the parties, and prepare the TPR return.
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05
Monitoring and support
We help update documentation and analyses, identify variances, process adjustments and prepare the company for a tax audit.
06 Benefits
Practical benefits for your business.
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Better risk oversight
Early identification of obligations, gaps and inconsistencies helps organise settlements before documentation or TPR is prepared, or before an audit begins.
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Consistent records and reporting
Agreements, calculations, invoices, ledgers, transfer pricing documentation and TPR data are reviewed as parts of one process.
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Clear group-wide rules
A transfer pricing policy defines calculation methods, mark-ups, allocation keys, responsibilities and documentation standards.
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Support through change and audit
Current documentation helps assess adjustments, restructurings and changes to the operating model, and supports the preparation of explanations for the tax authority.
07 Why inPL
Why work with inPL Group?
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01
A dedicated contact and access to a wider team
A designated person coordinates the engagement and can involve tax, accounting and finance specialists where required.
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02
Alignment with accounting records
We review transfer pricing documentation together with agreements, invoices, ledgers, calculations and the actual conduct of the parties.
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03
Experience with international structures
We support businesses operating in Poland, including Polish companies belonging to foreign groups.
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04
Insurance protection
Services are provided within the scope of the firm’s insurance cover and internal document-review procedures.
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05
Support in four languages
The engagement may be conducted in Polish, English, Ukrainian or Russian.
08 Related services
Transfer pricing connects with
accounting, audit and financial management.
09 Contact
Let’s discuss transfer
pricing in your business.
During the first consultation we discuss the group structure, transaction types and values, the tax year concerned and the current state of your documentation. We then outline the likely obligations, required data, timetable and fee proposal — with no commitment.
- Lublin 20-340, ul. Garbarska 18/10 +48 512 895 895
- Warszawa 02-188, ul. Janka Muzykanta 60 +48 784 971 203 +48 793 849 692 +48 534 315 931
- Kraków 31-509, ul. Aleksandra Lubomirskiego 39/1 +48 882 488 166 +48 571 807 904
- Katowice 40-082, ul. Sobieskiego 2 +48 514 375 043 +48 793 849 692
- Wrocław 54-203, ul. Legnicka 55F/356 +48 503 634 667 +48 534 315 931