
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.
We will prepare transfer pricing analyses (benchmarking / compliance analyses) to help you determine or verify the arm’s length level of remuneration for various types of intra-group transactions (services, goods, financial, licensing, etc.).
You can be sure of the high-quality of our benchmarks because:
Our qualitative analyzes will make you feel secure when signing and filing the statement on the preparation of transfer pricing documentation and the arm’s length nature of prices applied between related entities.
| Goods and service transactions | Simplified option | Standard option | Extended option | Extended option + COVID-19 impact / current economic situation |
| Assumptions for the review of arm’s length remuneration | Automatic data selection | Automatic and additionally a manual review of data on websites | Automatic and additionally a manual review of data on websites, including the recommended point from the range | Automatic and additionally a manual review of data on websites, including the recommended point from the range as well as the COVID-19 impact taken into account |
| Databases | External databases – Polish and European | External databases – Polish and European | External databases – Polish and European | External databases – Polish and European as well as publicly available data on the impact of COVID-19 |
| Outcome of works | Benchmarking report compliant with Polish tax regulations | Benchmarking report compliant with Polish tax regulations | Benchmarking report compliant with Polish tax regulations including the recommended point from the range | Benchmarking report compliant with Polish tax regulations including the recommended point from the range as well as conclusions from the COVID-19 impact analysis |
| Individual selection strategy | √ | √ | √ | √ |
| Automatic data selection | √ | √ | √ | √ |
| Additional manual data refinement | √ | √ | √ | |
| Additional calculations / adjustments to financial analysis | √ | √ | √ | |
| Indicating a recommended point from the range | √ | √ | ||
| COVID-19 impact analysis | √ | |||
| Support from MDDP experts | 2 h | 4 h | 4 h | 6 h |

Partner | Tax adviser | Head of the Transfer Pricing Practice E: magdalena.marciniak@mddp.pl T: (+48) 665 746 360

Partner E: magdalena.dymkowska@mddp.pl T: (+48) 501 108 261

Partner E: agnieszka.krzyzaniak@mddp.pl T: (+48) (22) 322 68 88

Senior Manager E: marta.klepacz@mddp.pl T: (+48) 533 889 036

Senior Manager E: adrian.mroziewski@mddp.pl T: (+48) 505 294 041

Manager E: jakub.patalas@mddp.pl T: (+48) (22) 322 68 88

Manager E: agnieszka.walska@mddp.pl T: (+48) (22) 376 52 86

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