Poland updates TPR guidance on cash pooling and reporting scope

The guide addresses version-six TPR-C and TPR-P forms. For corporate reporting, the underlying framework is Article 11t of the Corporate Income Tax Act and the Finance Minister’s Regulation of 29 August 2022. The November 2025 amendment replaced the regulation’s preparation instructions for tax years beginning after 31 December 2024. The new FAQ is recommended reporting guidance, not a general tax interpretation or a new charging rule.^{[1][2][3][4][5]}

For cash pooling, new question 153 explains that the average daily financing liability or receivable is calculated by adding actual closing daily balances and dividing by the days of actual participation in the arrangement. Positive and negative positions are reported separately. The calculation therefore needs the participant’s actual balance history and participation period, rather than simply the facility limit or one year-end balance.^[2][5]

Question 73 distinguishes aggregation from exemption. Article 11l(3) excludes transactions benefiting from Article 11n documentation exemptions when determining the value of a homogeneous controlled transaction. However, some documentation-exempt transactions still require separate TPR reporting under Article 11t. A documentation exemption should not be treated as a blanket reporting exemption.^[2][3]

The updated signing guidance includes the e-Urząd Skarbowy online route. TPR-C must be signed using a qualified electronic signature; the alternative authentication-data signature described for individuals’ TPR-P returns must not be applied to a company’s TPR-C. Groups should establish the correct form, authorised signatory and electronic route before filing.^[2]

The Ministry reiterates the existing eleven-month filing period: a calendar-year 2025 taxpayer’s TPR information is due on 30 November 2026. This publication is not a deadline extension. Separately, the September 2026 amending Act preserves specified earlier Article 11t content and signing rules for tax years beginning before 1 January 2026 and ending after 31 December 2025; its newer reporting changes must not be imported indiscriminately into the 2025 form.^[1][3][6]