Dynamic changes in regulations, along with the development of advanced analytical tools used by the National Revenue Administration (KAS), mean that the risk of tax audit verification of these settlements is becoming increasingly significant.
For most taxpayers, the deadline for preppering transfer pricing documentation for the 2025 financial year will fall on 31 October 2026, while the deadline for filing the TPR form with the Tax Office is 30 November 2026. We would like to remind you of the documentation obligations in the area of transfer pricing, which apply to transactions carried out, among others, within capital groups.
Starting work early allows taxpayers to avoid time pressure and proceed smoothly through the entire process.
Transfer pricing obligations apply to the following categories of transactions once threshold values are exceeded:
- Financial transactions – PLN 10 million
- Goods transactions – PLN 10 million
- Service transactions – PLN 2 million
- Other transactions (including non-cash transactions) – PLN 2 million
After exceeding the documentation thresholds, taxpayers are generally required to:
- prepare local transfer pricing documentation (Local File),
- prepare a benchmarking analysis or compliance analysis,
- submit transfer pricing information (TPR),
- in some cases – maintain group documentation (Master File).
What are the key deadlines?
In accordance with applicable regulations, companies have a defined period to prepare and submit transfer pricing documentation for a given tax year. Failure to meet these deadlines may result in penalties.
- Preparation of local file documentation – by the end of the 10th month following the end of the tax year (by 31 October 2026 for entities whose tax year is the same as the calendar year).
- Submission of TPR-C information – by the end of the 11th month following the end of the tax year (by 30 November 2026 for entities whose tax year is the same as the calendar year).
- Preparation of master file documentation – by the end of the 12th month following the end of the tax year (by 31 December 2026 for entities whose tax year is the same as the calendar year).
KR Group support
Our experts provide support in: verification of documentation obligations, preparation of Local File and Master File documentation, benchmarking and compliance analyses, and preparation of TPR information. We advise on transfer pricing policy design, transactions with related parties, and we represent clients in dealings with tax authorities.
If you would like to discuss potential support in the areas of transfer pricing, taxation, and accounting, we invite you to contact us. We will be happy to present solutions tailored to the specifics of your business.
Why choose KR Group?
At KR Group, we also support entrepreneurs in day-to-day accounting, financial reporting, tax settlements, and fulfilment of documentation obligations arising from transfer pricing regulations.
By combining these competencies, our clients gain a single partner responsible for key financial and tax areas of their business. Our portfolio includes some of the most reputable international companies that are leaders in their industries, such as real estate, retail, manufacturing, investment funds, IT, gas exploration and production, renewable and conventional energy, automotive, and FMCG.
