When to File Transfer Pricing Documentation for 2021

When to File Transfer Pricing Documentation for 2021

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Under the CIT Act, taxpayers are normally required to file the TPR form and a statement on the preparation of the local file for 2021, by the end of the ninth month after the end of the financial year.

However, on 28 April 2022, the Sejm passed a bill amending certain acts to automate the handling of certain matters by the National Tax Administration.

The bill includes an amendment to the so-called COVID Act in respect of the extension of deadlines for the submission of statements on the preparation of transfer pricing documentation and the filing of TPR forms for 2022.

The Act on amending certain acts to automate the handling of certain matters by the National Tax Administration extends the above deadline:

  • until 30 September 2022 – for TPR forms and statements on the preparation of the local file, with a submission deadline between 1 January 2022 and 30 June 2022, and
  • by 3 months – for TPR forms and statements on the preparation of the local file, with a submission deadline between July 2022 and 31 December 2022.

In practice, for entities whose tax year ended on 31 December 2021, the deadline for filing the TPR form and transfer pricing statement will be 31 December 2022.

We provide assistance with both the preparation of transfer pricing documentation and transfer pricing reporting for 2021.

We would also like to remind you that for transactions effected after 1 January 2022, the Polish Deal Act introduced a new deadline for:

  • preparation of the local file – by the end of the 10th month after the end of the tax year; and
  • filing of the transfer pricing report together with a statement on the preparation of the local file – by the end of the 11th month after the end of the tax year.

By Agata Dziwisz, Partner, and Katarzyna Pustulka, Junior Associate, Kochanski & Partners