Below we present the most important changes in transfer pricing documentation taking effect from January 1, 2019:
1. New transaction thresholds for Local file
The costs and revenues thresholds determining the scope of the TP obligations are eliminated. The new transaction thresholds are:
2. New rules regarding Master file
Pursuant to the new provisions, the obligation to prepare group documentation (Master File) concerns entities that jointly meet the below conditions:
Master File may be drafted in English but the tax authorities may request a Polish translation. If requested, the Polish version should be filed within 30 days.
3. New deadlines for preparing TP documentation
From 2019 taxpayers have 9 months from the end of the tax year to prepare local documentation and 12 months to prepare group documentation.
4. Simplifications for low value adding services and loans
Simplified solutions are applying to:
5. Documentation exemptions
The new regulations also provide for the exemption from the documentary obligation of transactions concluded by domestic related entities. Taxpayers are now able to take advantage of this exemption if each party to the transaction declares income in a given tax year and does not benefit from income tax exemption in connection with the activity conducted in a special economic zone.
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