Transfer pricing 2026 — who must prepare documentation?
If you transact with related parties, above the statutory thresholds you must prepare transfer pricing documentation and file the TPR form. We explain who is covered and how to prepare.
Who is covered
Transfer pricing rules govern settlements between related parties (e.g. group companies, a shareholder and the company). The documentation obligation arises once the statutory value thresholds for transactions in a year are exceeded.
- PLN 10 million — commodity and financial transactions.
- PLN 2 million — service and other transactions.
- Lower thresholds and special rules for transactions with so-called tax havens.
- Thresholds are counted separately for each homogeneous transaction.
What you need to prepare
- Local documentation (local file) for transactions above the thresholds.
- A benchmarking study confirming that prices are at arm's length.
- The TPR information filed with the tax office.
- In specific cases, group documentation (master file).
Deadlines and sanctions
As a rule, the TPR information and the statement on preparing the documentation are filed by the end of the 11th month after the tax year ends, and the local file is prepared within the same deadline (to be produced on request). Missing documentation risks income reassessment, interest, and fiscal-penal liability of board members.
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