The last effort – the Master File…

Unfortunately, some taxpayers will not find the beginning of the year to be a relief after a demanding December which was packed with transfer prices matters. In fact, some may even face the need to complete further activities. One of them is the preparation of the Master File.

Who is subject to the documentation obligation?

The obligation to prepare the Master File applies to related entities consolidated using the full or proportional method which meet two conditions:

  1. they prepare consolidated financial statements,
  2. their consolidated revenues exceeded PLN 200 million or its equivalent in the previous financial year.

However, the statutory requirement applies only if the taxpayer meets the conditions for preparing the local file (both documents are filed with the tax authority in the event of an inspection).

As a rule, the documentation can be prepared in a foreign language (the act only mentions English), but the tax authority may request its translation into Polish to be filed within 30 days. It is worth remembering that if you belong to a non-English group and receive the Master File in its language, it should be translated into Polish.

For example, if the group parent company has its registered office in a Scandinavian country (in particular in Denmark, Finland, Sweden), then the documentation for the group is most often prepared in their native language. This creates an additional challenge in terms of mandatory translation.

Moreover, the Master File should be complete and contain all the elements required by Polish tax regulations. Having it prepared by another group entity does not release from the responsibility for compliance of the documentation with the CIT Act.

Problems faced when preparing the Master File

The seemingly simple document can cause many difficulties, especially in the context of international exchange of information and cooperation in a group. Not to mention the differences in terms of formal obligations under Polish income tax regulations and those resulting from foreign jurisdictions.

First of all, Polish taxpayers should carefully analyze and, if necessary, adjust the Master File for compliance with their own Local File. It is an integral part of the full transfer pricing documentation package and should feature consistent information about the entire group of related entities. During a possible inspection, the authorities will be assessing the compliance and consistency of information provided across documents.

If the deadline in the country of the registered seat of the entity preparing the Master File is longer than in Poland, the taxpayer should take prior and necessary actions to obtain the information required to complete the file on its own.


The deadline for completing the Master File for 2021 has been extended to the end of the third month, counting from the day following the deadline for filing the statement on having prepared the Local File.

Thus, if an entity’s financial year ends on 31 December, the postponed deadline is 31 March 2023.


The Master File is a document that requires obtaining and then filing a lot of hard-to-reach information that is often only available at the group level. Therefore, it is worth asking for professional support well in advance. It may become necessary not only at the stage of preparations, but also for determining the type of data required.

Nina Walczyk

Nina Walczyk

Senior Consultant in the Transfer Pricing Team | Attorney at Law

Tel.: (+48) 503 975 166