Transfer Pricing Obligations in Poland – Time Is Running Out for TPR and the Local File 2024

Deadlines for transfer pricing obligations in Poland – TPR form and the Local File for 2024 – are approaching fast. Find out how much time is really left, which mistakes to avoid, and why acting now – before the end of summer – is your best option.

Only 60 days after the summer break

That’s exactly how much time will be left when September begins and calendars fill up with meetings, deadlines and daily tasks:

• 60 days to prepare the Local File (local transfer pricing documentation)
• 90 days to file the TPR form for FY2024
• 0 margin for errors, rush decisions or oversights

These deadlines apply to taxpayers whose tax year aligns with the calendar year. See our TP calendar for 2025 (PDF – English version) for all relevant deadlines related to FY2024 transfer pricing obligations.

While the obligations may seem technical, their consequences are very real. They include:

• the requirement to update benchmarking studies,
• ensuring consistency between Group-prepared documentation and Polish CIT rules,
• identifying and documenting non-standard transactions such as guarantees, recharges, transactions with individuals, and transactions with tax haven entities.

At the end of this process comes the TPR form – signed by the management board with full legal and tax liability,  including potential criminal liability for those responsible for the company’s finances. That is not the time for uncertainty.

TPR 2024: How it triggers tax audit risk

For the Polish tax authorities, the TPR form is not just a formality. It’s a risk assessment tool.

A well-prepared form may go unnoticed. But one with errors or inconsistencies is automatically flagged by the Customs and Tax Control Offices (UCS).

What might raise red flags?

• errors in benchmarking studies
• unusual financial results
• inconsistent data
• information on transactions with shareholders

An audit may be initiated in a few months – or years. The documentation must always be audit-proof, and the finance team must know how to explain it.

How about… not waiting until September?

Today is 14 July. That means:

• 109 days left to prepare the Local File
• 139 days left to file the TPR form

That’s nearly double the time compared to starting in September.

With that advantage, you can:

• collect data from the Group calmly and thoroughly,
• prepare or update benchmarking studies,
• identify risks and mitigate them before submitting the TPR form,
• conduct an internal review – or obtain a second opinion,
• plan your TP documentation for 2024 step by step before the September rush.

You can’t do this overnight. But you can do it calmly – if you start today.

What do we know about tax audits – and why does it matter?

While preparing our joint report with “Lewiatan” Confederation (PDF- Polish version, English version coming soon), we received exclusive data from the Polish Ministry of Finance on transfer pricing audits in 2024.

We know which transactions are being audited most often – and how to prepare for it.

Practical experience – tested in the field

In our 2025 case law review (PDF – Polish version, English version coming soon), we:

• summarise 15 key rulings issued by Polish administrative courts (WSA and NSA),
• analyse their implications for documentation, adjustments and the TPR form,
• include expert commentary from our team,
• explain what tax authorities actually verify during audits.

Throughout our more than 20-year history, our benchmarking analyses have consistently remained unchallenged during audits or Advance Pricing Agreement (APA) procedures – in Poland or abroad.

Each project is led by a Partner from start to finish. That’s our guarantee of quality and accountability.

Use the time advantage

If you wait until September – you’ll have 60 days.
Start now – and you’ll have over 100.

Don’t let the pressure of autumn dictate your transfer pricing decisions. Let’s approach it together – with clarity, confidence and care.

Contact us – the MDDP transfer pricing team is ready to support you.

No advisor yet? Now is the right time to choose one.
Already working with someone? Great – if needed, we’re happy to support with experience and a fresh perspective > www.mddp.pl/transfer_pricing