Changes in transfer pricing – new TPR rules for companies
The government's draft transfer pricing changes proposes to eliminate the requirement to submit a declaration in the TPR return confirming that local transfer pricing documentation has been prepared in accordance with the actual state of affairs. Once the new regulations come into force, this declaration will remain part of the Local File, but it will no longer be submitted to the tax authorities as part of the TPR information. This change is the starting point for a series of further simplifications regarding transfer pricing reporting.
The draft changes to transfer pricing in brief
According to the Ministry of Finance, the simplified TPR information will apply to reporting for 2026. The act itself is scheduled to enter into force 14 days after its publication. The January 1, 2027 deadline applies to other solutions included in the bill, not related to transfer pricing reporting.
The bill provides simplifications primarily regarding Tax Returns (TPR) information. Micro- and small-sized businesses will no longer be required to report their financial situation in the TPR. The TPR information can be signed by a proxy authorized to sign electronic returns, and TPR corrections will be made in accordance with the principles set forth in the Tax Ordinance. The solutions described are not yet in force, so their final scope may change in the subsequent legislative process.
The government has adopted a draft amendment to transfer pricing. What does this mean for entrepreneurs?
The government has adopted a draft amendment to the Personal Income Tax (PIT) and Corporate Income Tax (CIT) Acts, which provides for a number of simplifications in the area of transfer pricing. While there will be no revolution, many companies will experience a tangible reduction in the burden of preparing TPR information. The changes will be of particular interest to micro- and small-scale entrepreneurs, as well as capital groups, which face transfer pricing documentation obligations every year.
The most important changes in transfer pricing
Let us check what changes are planned in the project and when they will come into effect.
The draft amendment focuses primarily on simplifying obligations related to transfer pricing information (TPR). This form has raised the most practical concerns for years and requires taxpayers to collect a wide range of data.
The most important changes include:
- limiting the scope of data reported in the TPR by micro and small enterprises,
- simplification of the rules for signing TPR information,
- the possibility of correcting TPR according to the general principles arising from the Tax Ordinance,
This is the next stage of deregulation activities aimed at reducing tax compliance costs for entrepreneurs.
The project includes several significant changes intended to simplify transfer pricing obligations. The table below presents the most important changes and their practical implications for businesses.
| Area of change | What is changing? | What does this mean for an entrepreneur? |
|---|---|---|
| TPR Information | Micro and small entrepreneurs will not disclose general financial information | A shorter and less complicated TPR preparation process |
| Signing the TPR | The form may be signed by a proxy with a UPL-1 power of attorney, i.e. also by a proxy who is not an attorney, expert or legal counsel. | Greater organizational flexibility and the ability to delegate responsibilities |
| TPR Correction | The general provisions of the Tax Ordinance will apply to corrections. | Easier error correction and greater legal certainty |
| Documentation-exempt transactions | The scope of data reported in the TPR will be limited | Fewer reporting obligations for selected transactions |
| Entry into force | The changes are to apply to TPR information submitted for tax years beginning after December 31, 2025. | It is worth preparing the reporting process for the new rules now. |
Does a micro-entrepreneur have to report financial data in the TPR?
No. According to the project, micro and small entrepreneurs will not be required to report general indicators describing their financial situation in the TPR.
Currently, taxpayers are required to disclose, among other things, selected financial data and indicators used by the tax administration for risk analysis. In practice, preparing this information can be time-consuming and often requires additional analysis.
After the new regulations come into force, entrepreneurs who meet the definition of a micro or small entrepreneur in accordance with the Entrepreneurs' Law will not have to complete this part of the form.
For many entities this means:
From a reporting practice perspective, limiting the number of required indicators should reduce the workload required to prepare the TPR by smaller entities.
Will it be possible to sign the TPR through a UPL-1 proxy?
Another significant change concerns the method of signing TPR information.
So far, the regulations provided for specific rules for signing the form, which in practice caused many organizational problems, especially in large capital groups.
Following the changes, the general rules of the Tax Ordinance will apply. This means that the power of attorney to sign electronic returns (UPL-1) will also include TPR information, meaning even an attorney who is not an attorney, expert witness, or legal counsel can sign it.
For businesses, this means greater organizational flexibility and a simplified reporting process. In practice, many companies will be able to more effectively delegate transfer pricing responsibilities to specialized individuals or advisors.
Easier correction of TPR information
The draft also explicitly applies the provisions of the Tax Ordinance regarding corrections to TPR information. This should reduce the risk of interpretation disputes regarding how to correct previously submitted forms.
Less data for transactions benefiting from exemptions
The project also provides for a limitation of the scope of information disclosed in the TPR for selected categories of transactions benefiting from documentation exemptions.
In such cases, taxpayers will not have to report some financial data and information on transfer pricing verification methods.
While the change may seem technical, in practice it means further simplification of the reporting process and reduction of the number of fields that need to be completed.
Do the changes mean fewer transfer pricing obligations?
Not entirely. Entrepreneurs should remember that the draft does not eliminate basic transfer pricing obligations. It will still be necessary to:
- identifying controlled transactions,
- verifying documentation thresholds,
- preparation of local transfer pricing documentation (Local File),
- maintaining the market nature of settlements between related entities,
- preparation of comparative analyses where required.
The changes primarily concern reporting and administrative formalities. However, they do not relieve taxpayers of the obligation to demonstrate that the prices they apply reflect market conditions.
When will the new transfer pricing regulations apply?
According to the draft, the TPR simplifications are to apply to information submitted for tax years beginning after December 31, 2025.
The deadline for submitting TPR information is the end of the 11th month after the end of the tax year. For a tax year that follows the calendar year, this means that TPR information for 2025 is submitted in the fourth quarter of 2026, meaning businesses will be able to utilize some of the new solutions for their upcoming reporting obligations.
At the same time, on 1 January 2027, the abolition of sanctions in PIT and CIT for payments made without the "white list" or the split payment mechanism comes into force, however, this does not apply to TPR.
How to prepare your company for upcoming changes?
Although the project is intended to deregulate, it is not worth waiting until the last minute. Businesses should now:
Summary: Simplifications do not absolve us from responsibility.
The proposed changes do not alter the fundamental principle of transfer pricing. Transactions between related entities must still be conducted on market terms and properly documented. Tax authorities will still be able to verify both the pricing method and the completeness of the documentation.
From the perspective of entrepreneurs, it is worth using the period preceding the entry into force of the new regulations to review the applicable transfer pricing procedures.
At Crowe Poland, we observe that the biggest challenge for companies is not simply preparing the TPR form, but rather effectively managing the entire transfer pricing process - from identifying controlled transactions, through preparing documentation, to accurate reporting. Therefore, administrative simplifications should be treated as an opportunity to streamline processes, rather than as a signal that transfer pricing requires less attention.
FAQ – changes in TPR – frequently asked questions
No. The draft does not eliminate TPR information, but simplifies selected obligations related to its submission and the scope of data.
According to the project, micro and small entrepreneurs will not have to disclose general financial information of the entity in the TPR information.
Yes. The draft stipulates that the power of attorney to sign electronic declarations, i.e. UPL-1, will also cover TPR information.
The new rules will apply to TPR information submitted for the tax year beginning after December 31, 2025.
Yes. The simplifications in the TPR do not remove the obligation to verify controlled transactions, documentation thresholds, Local File documentation, or the arm's length principle.
