
Year-end in transfer pricing – obligations, risks and key actions for 2025/2026
Year-End in Transfer Pricing: Key Documentation Obligations and Actions for 2025/2026 to Minimise Tax Risk.

Cost segregation is a detailed identification of fixed assets based on tax regulations and Polish Fixed Assets Classification as well as determining the initial value of fixed assets including indirect costs.
| Goals | Benefits |
Depreciation of fixed assets | Higher depreciation rates available. |
| Real Estate tax | Precisely defined structures to be taxed and their tax base. For an investment located in several communes, tax base is determined for each commune. |
| Preparing real estate (investment) for sale | Transparent structure of fixed assets and better results in due diligence ordered by a buyer. |
| Inventory of property | Property review and the possibility of professional marking of fixed assets. |
| Real Estate clause | In practice, it often turns out that after cost segregation the entity does not meet the definition of a real estate company and the clause does not apply. |
| Fixed Assets | Initial value | Depreciation rate | Depreciation | Minimal CIT on Real Estate | ||||
| Before | After | Before | After | Before | After | Before | After | |
| Wind farm | 1000 | 4,50% | 45 | 20 | 2 | |||
| Foundation for the turbine | 100 | 4,50% | 4,5 | 5 | ||||
| Turbine tower | 250 | 4,50% | 11,25 | 0 | ||||
| Turbine nacelle with generating set | 250 | 7% | 17,5 | 0 | ||||
| Blade and hub | 200 | 7% | 14 | 0 | ||||
| HV cables | 150 | 4,50% | 6,75 | 0 | ||||
| GPO | 50 | 10% | 5 | 0 | ||||
| Total | 1000 | 1000 | 45 | 59 | 20 | 7 | ||
Increasing monthly depreciation write-offs up to 2 times.
Up to 3-fold reduction in Real Estate tax on structures.

Partner | Tax adviser
E: rafal.kran@mddp.pl
T: +48 693 290 919

Manager
E: lukasz.szatkowski@mddp.pl
T: +48 570 898 499

Year-End in Transfer Pricing: Key Documentation Obligations and Actions for 2025/2026 to Minimise Tax Risk.

Avoiding a ‘delayed time bomb’: how master file documentation impacts

On December 1, 2025, the Minister of Finance and Economy