TP Obligations 2024: deadlines, documentation and consequences for taxpayers

Why TP obligations for 2024 matter for businesses

The upcoming autumn marks the need to fulfil transfer pricing obligations for 2024. Businesses are required to prepare the Local Transfer Pricing Documentation (Local File) for 2024 and keep in mind the upcoming deadlines relating to the TPR form and the Group Transfer Pricing Documentation (Master File). Insufficient preparation may result in financial penalties and fiscal-criminal liability, therefore it is advisable to take action well in advance.

Local Transfer Pricing Documentation (Local File) – deadlines and risks

One of the key transfer pricing obligations for 2024 is the preparation of Local Transfer Pricing Documentation (Local File). It must be prepared by the end of the 10th month following the end of the financial year, i.e. by 31 October 2025, if the financial year coincides with the calendar year. This documentation is submitted to the tax authorities only upon request – and within a very short deadline of 14 days. Delays in preparing the Local File may therefore prove risky, especially if the documents are only drafted once the request is received.

TPR Form for 2024 – what to include and when to submit

The TPR form for 2024, i.e. transfer pricing information, must be submitted by 1 December 2025 (provided the financial year coincides with the calendar year). The statutory deadline falls at the end of the 11th month following the end of the financial year; however, in this case, 30 November falls on a Sunday. The TPR form is a key TP obligation as it contains detailed data on transactions with related entities and constitutes one of the main sources of information for the tax administration. Incorrect or late filing of the TPR form may result in serious consequences – as it is used to select entities for tax audits. It is therefore crucial to ensure accuracy and consistency of the data reported in the TPR with the Local File documentation.

Group Transfer Pricing Documentation (Master File) – who must prepare it

Entities belonging to capital groups whose consolidated revenues exceeded PLN 200 million in the previous financial year must hold Group Transfer Pricing Documentation (Master File). In this case, the deadline for preparation is 31 December 2025.

The Master File is usually provided by the group’s headquarters and may be prepared in English – translation into Polish is only required upon request by the tax authorities. However, it is essential that the content of the Master File aligns with the information presented in the Local File. Discrepancies between the two may raise concerns from the authorities and increase the risk of an audit.

Consequences of lack of documentation and delays

Failure to comply with transfer pricing obligations for 2024 carries significant consequences. Sanctions include additional tax assessments, financial penalties, and fiscal-criminal liability of those responsible for related-party transactions – in particular management board members.

The most common infringements include:

• failure to prepare a Local File or a Master File,
• failure to submit the TPR form on time,
• providing false information in the documentation or the form.

How to prepare for TP obligations 2024 – practical guidance

To efficiently meet your TP obligations for 2024:

• start work on the Local File well in advance,
• ensure accurate preparation of the TPR form,
• coordinate Master File work with the group’s headquarters,
• verify the consistency of all documents and reports,
• seek support from tax advisors to minimise risks.

Summary and call to action

TP obligations for 2024 require diligence and timeliness. For taxpayers whose financial year coincides with the calendar year, the key dates are: 31 October (Local File), 1 December (TPR form, ordinarily 30 November with exceptions for weekends and holidays), and 31 December (Master File). Delays or errors may result in severe consequences. It is therefore worth starting preparations today.

Do you have questions about transfer pricing obligations for 2024? Contact our team – we will help you prepare the documentation and the TPR form within the required deadlines.