Transfer pricing information for 2021 until 31 December 2022

The deadline for submitting the transfer pricing information for 2021 for entities with a tax year coinciding with the calendar year is coming up soon. There is slightly more time for companies to compile their Master File group documentation.

The statutory deadlines for preparing transfer pricing documentation for 2021 and submitting the required reporting forms to the relevant tax authority are approaching.

The regulations on transfer pricing documentation, require companies to prepare or update the information by the end of the ninth month following the end of the tax year documented. However, this deadline has been extended by three months.

Deadlines for preparing and submitting transfer pricing information for 2021:

31 December 2022 - deadline for preparing the documentation and submitting the transfer pricing statement together with TPR-C form for entities with a tax year coinciding with the calendar year,
End of March 2023 - deadline for preparing the group documentation, the so-called Master File.

The transfer pricing information (TPR) contains a range of data, including the tax office to which it is submitted, information on the purpose of documentation submission and the period (year) for which the information is compiled.

Transfer pricing - who must report?

The obligation to prepare and submit transfer pricing information concerns related parties, i.e., inter alia, entities one of which exerts significant influence over another, group companies and foreign establishments that are part of the group.

Thus, the preparation of transfer pricing documentation is an obligation for taxpayers making settlements and transactions with related parties and with entities registered in tax havens, in situations in which the documentation thresholds indicated in the provisions of the tax acts are exceeded.

Meeting the deadlines for reporting TPR transfer pricing information is very important. Penalties and sanctions for failing to do so can be severe, and fiscal criminal liability related to TPR rests with both the company as a taxpayer and those responsible for complying with the company's obligations. Submission of transfer pricing documentation after the deadline may cost the taxpayer more than PLN 9 million.