As of 2020, Polish taxpayers will have to provide the National Revenue Administration with a new declaration – TP-R form (transfer pricing information). Given the scope of the detailed data and information to be reported as part of transfer pricing information, from the perspective of tax authorities it will be an ideal tool for identifying transactions that will later be verified during a tax audit.
The TP-R form must contain very detailed information (including very specialized transfer pricing data) including, among others: values of financial indicators measuring the taxpayer’s financial position, information on related entities and controlled transactions, information on the transfer pricing method used for verification of the market price as part of the transactions subject to inspection and the results of comparative analyses.
Therefore, it may be very difficult for taxpayers to correctly fill in and submit transfer pricing information. It should also be noted that the lack of preparation of the TP-R form, submitting a false declaration or submitting it after the deadline exposes the taxpayer to severe tax sanctions: potentially up to PLN 20 million. Therefore, it is necessary to exercise due diligence in properly fulfilling all TP-R reporting obligations.
