
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.

SLIM VAT 2 is an amendment to the VAT Act introducing changes in the following areas among others:
Recent changes in VAT often cause more uncertainty for taxpayers, although they were intended to serve as simplification in response to taxpayers’ problems.
The SLIM VAT 2 package involves a number of changes that may result in your company in:
Above all, however, the new regulations pose a challenge to persons in charge of appropriate recognition of business transactions in tax settlements of entities.
Compliance of settlements with the latest regulations, in particular in relation to the successive changes as regards corrective invoices
Clarity on complex business transactions difficult to classify related, for instance, to supplies involving several entities in the chain or sales to the UK
Ability to recover interest paid as a result of applying the so-called "separate recognition” effective prior to SLIM VAT 2 with regard to ICA and importation of services
Your company's awareness of the “weaker sides” of the new regulations and the problems that may arise from them in your tax returns
Taking advantage of the possibility of applying the new bad debt relief regulations and recognising input tax after the period set for invoice recognition on an ongoing basis.

Partner | Tax adviser | Head of the VAT PracticeE: tomasz.michalik@mddp.plT: (+48) 501 733 720

Partner | Tax adviserE: janina.fornalik@mddp.plT: (+48) 660 440 141

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