Poland enacts simpler transfer-pricing reporting

The TPR declaration is removed

The Act deletes the declaration currently embedded in transfer-pricing information that the local file reflects the facts and that documented transfer prices are arm's length. It removes the relevant reporting item and associated signing provisions from Article 11t of the Corporate Income Tax Act and the parallel Article 23zf of the Personal Income Tax Act. The underlying arm's-length and documentation rules are not repealed: the change removes a separate declaration from the TPR filing rather than relaxing the substantive pricing standard.^[1][2][3]

The adjustment condition is narrowed for domestic parties

Amended Corporate Income Tax Act Article 11e(4), and the parallel Personal Income Tax Act Article 23q(4), require a legal basis for exchanging tax information with the other entity's jurisdiction where that related party is not resident or managed in Poland. The cross-border condition will therefore no longer be imposed where the related party is domestic. The Act does not displace the other statutory requirements for making a downward transfer-pricing adjustment.^[1][2][3]

Signing authority and data fields are simplified

An electronic-declaration power of attorney will also authorise the signing of TPR information, and the Tax Ordinance's correction rules will apply correspondingly to TPR submissions. Micro and small enterprises will not include general financial information where they met the relevant enterprise-status test in the preceding tax year. For specified transactions already exempt from the local-file obligation, prescribed financial and transfer-pricing-method fields will also be omitted. These are targeted reporting reductions, not a general exemption for controlled transactions.^[1][2][3]

The new reporting rules apply to 2026 tax years

The amended TPR provisions apply to tax years beginning after 31 December 2025. The former rules continue for a tax year that began before 1 January 2026 and ends after 31 December 2025, which matters for non-calendar-year groups. Existing implementing regulations remain in force until replacements take effect, but no later than 30 June 2027. The Act generally enters into force 14 days after publication; separate non-transfer-pricing provisions concerning invoice payments and tax costs start on 1 January 2027.^[1]

Groups should revise 2026 filing controls

Multinational groups should identify Polish entities eligible for the micro- or small-enterprise reduction, revise signatory mandates and preserve evidence supporting arm's-length pricing even though the declaration is removed. They should also separate calendar-year entities from taxpayers within the transitional rule before changing TPR templates. The narrower form does not eliminate local-file obligations or the need to support controlled transactions; it changes who may sign and which fields must accompany the information return.^[1][2][3]