POLAND: EXPANDED TRANSFER PRICING, COUNTRY-BY-COUNTRY REPORTING ENACTED

New law in Poland expands the requirements for transfer pricing documentation, and includes country-by-country (CbC) reporting. The new provisions essentially reflect the recommendations made in Action 13 the OECD’s base erosion and profit shifting (BEPS) project, and provide for CbC, master file and local file reporting.

The legislation was passed by the lower house (Sejm) in September 2015, and sent to the upper house for consideration. Following this, the president signed the bill into law. Read more on the then-pending amendments to the transfer pricing reporting rules: TaxNewsFlash-Transfer Pricing

Read a 2015 report [PDF 299 KB] (English) or a 2015 report [PDF 293 KB] (Polish): Transfer Pricing Alert

• Master file: The threshold is €20 million and it is binding from 2017.
• Local file including local benchmarking (comparables) is binding from 2017.
• CbC is binding from 2016.