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Since 1 January 2017 new documentation obligations apply in terms of transfer pricing. One of them involves filinga CIT-TP form together with an annual statement by the taxpayer. This obligation applies to taxpayers who must prepare tax documentation and whose income or costs in a given tax year exceeded 10 million euro.

The final version of CIT-TP statement was publishedon 8 June 2017 pursuant to the Decree of the Minister of Development and Finance on defining the template of a simplified statement in terms of corporate income tax.

The CIT-TP form will be a tool allowing tax authorities to select entities to be audited.

While preparing the CIT-TP form, which consists of more than 140 items, the taxpayer must state: capital group details, types of relations, number of related entities with whom transactions have been made, information concerning business restructurings, as well as information concerning transactions made with related entities (inter alia indicate their net value or country codes for countries where the parties to a transaction have registered seats). The values of transactions must be indicated as per accounting treatment, in book values.

In many cases, preparing the CIT-TP form might require detailed or even specialized transfer pricing knowledge, for instance to define the taxpayer’s functional profile or identify restructuring actions implemented.

The responsibility for the failure to provide the true and fair view of the taxpayer or failure to submit the CIT-TP form has to be taken into account. Such actions might trigger sanctions under penal fiscal code.

Having a properly prepared CIT-TP form may limit the risk of taxpayer’s settlements made with related entities being scrutinized and audited. Therefore, it is recommended to already take care of the preparation process, also from the technical point – for instance by adjusting accounting systems and grouping transactions to match the CIT-TP form requirements.



If you are interested in the above information, please contact us at:

Alicja Sarna tel. + 48 22 322 68 88,

Magdalena Marciniak tel. + 48 22 322 68 84

or the Company’s MDDP advisor.

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