Transfer pricing in 2026 – Local File, TPR and Master File deadlines for FY 2025

Although transfer pricing deadlines are a permanent feature of the tax calendar, they still tend to surprise taxpayers each year. However, documentation obligations can be planned  well in advance. For this reason, related parties should ensure timely verification of their controlled transactions, applicable documentation thresholds, and available exemptions.

Key transfer pricing deadlines in 2026

In 2026, taxpayers whose tax year coincides with the calendar year will fulfil their transfer pricing obligations for transactions carried out in 2025.

For taxpayers with a calendar-year tax period, the key deadlines are as follows:

• 2 November 2026 (postponed due to the statutory deadline falling on a weekend) – preparation of the Local File (local transfer pricing documentation),
• 30 November 2026 – submission of the TPR transfer pricing information form,
• 31 December 2026 – preparation of the Master File (group transfer pricing documentation).

This article focuses on corporate income taxpayers (CIT) submitting the TPR-C form. Personal income taxpayers (PIT) submit the TPR-P form under analogous rules.

Local File for 2025 – deadline 2 November 2026

The Local File have to be prepared in electronic form by the end of the tenth month following the end of the tax year.

As 31 October 2026 falls on a Saturday, for taxpayers whose tax year ended on 31 December 2025, the deadline is extended to the next business day, i.e. 2 November 2026.

The purpose of the Local File is to demonstrate that transfer pricing applied in transactions between related parties was determined on terms that would have been agreed between unrelated entities.

Local File documentation thresholds

Local transfer pricing documentation have to be prepared for a homogeneous controlled transaction where the value in the tax year exceeds the relevant threshold:

• PLN 10,000,000 – for commodity or financial transactions,
• PLN 2,000,000 – for service transactions,
• PLN 2,000,000 – for other transactions.

Thresholds are determined separately for each type of homogeneous controlled transaction and separately for the cost and revenue side.

Transactions with entities located in tax havens

Lower thresholds apply to certain transactions with entities having their place of residence, registered office or place of management  in jurisdictions applying harmful tax competition.

In such cases, the documentation thresholds are:

• PLN 2,500,000 – for financial transactions,
• PLN 500,000 – for non-financial transactions.

Rules concerning tax haven jurisdictions may also apply to transactions that are not classified as controlled transactions. Therefore, both the counterparty status and the nature of the transaction must be assessed on a case-by-case basis.

Exemption from requirement to prepare Local File

Exceeding the documentation threshold does not automatically trigger the obligation to prepare a Local File. The Polish Corporate Income Tax Act (CIT Act) provides several exemptions, subject to specific conditions.

The most commonly applied excemption is the one for domestic transactions under Article 11n(1) of the CIT Act (and Article 23z of the PIT Act in the case ofindividuals). It applies to transactions conducted exclusively between related parties that are Polish residents.

As a general rule, during the relevant period none of the participants may:

• benefit from the exemption under Article 6 of the CIT Act (or Articles 21(1)(63a) and (63b) of the PIT Act),
• benefit from income tax exemptions under the Special Economic Zone (SEZ) regime or pursuant to a Decision on Support (applicable to CIT taxpayers),
• incur a tax loss.

Eligibility for the exemption must be assessed individually for each entity and transaction.

Other exemptions from requirement to prepare Local File

Exemptions may also apply, inter alia, to transactions:

• between companies forming a tax capital group,
• where the relationship arises solely from links with the State Treasury or local government units,
• where the price was determined through an open tender procedure,
• covered by an advance pricing agreement (APA),
• meeting safe harbour conditions.

Should exempt transactions be reported in the TPR form?

Exemption from Local File preparation does not automatically mean exemption from filing the TPR form. For exempt transactions, the scope of data reported in the TPR form may be reduced, but reporting obligations may still apply.

Accordingly, it should not be assumed that no Local File obligation also means no TPR filing requirement.

Transfer pricing analysis in the Local File

As a general rule, one of the key elements of the Local File is the transfer pricing analysis.

Its purpose is to demonstrate that the conditions applied in controlled transactions correspond to those that would have been agreed between unrelated parties.

Transfer pricing analysis may take one of two forms.

Benchmarking analysis

A benchmarking analysis compares the conditions of a controlled transaction with:

• transactions between the taxpayer and unrelated parties,
• transactions between independent entities,
• financial results of comparable companies.

Its preparation requires defining comparability criteria and selecting appropriate financial or transactional data.

Compliance analysis

A compliance analysis is prepared where, despite due care, a benchmarking analysis cannot be performed or is not appropriate for various reasons.

It must demonstrate that the terms of the controlled transaction are consistent with those that would have been accepted by unrelated parties in comparable circumstances.

As a rule, transfer pricing analysis forms part of the Local File. However, in certain cases regulations allow for exemptions, including for micro and small enterprises meeting the criteria under Article 7(1)(1) and (2) of the Entrepreneurs’ Law. Application of such simplifications requires separate assessment.

TPR for 2025 – deadline 30 November 2026

The next obligation is the submission of the transfer pricing information form, i.e. TPR-C (for CIT taxpayers) and TPR-P (for PIT taxpayers).

The form must be submitted electronically to the competent Head of the Tax Office by the end of the eleventh month following the end of the tax year.

For taxpayers with a calendar-year tax period, the deadline for submitting the TPR for 2025 is 30 November 2026.

What information does the TPR include?

The TPR form includes, inter alia:

• taxpayer identification data,
• basic financial information,
• information on related entities,
• data on reported controlled transactions,
• information on applied transfer pricing verification methods.

Where transactions are subject to Local File requirements, the form also includes a declaration confirming that the documentation has been prepared in accordance with the factual state of affairs and that transfer prices were set on arm’s length terms.

Given the scope of reported data and the declaration required, preparation of the TPR should not be left until the end of November. The data must be consistent with the taxpayer’s records, including Local File documentation, transfer pricing analysis, contracts, and financial statements.

Master File for 2025 – deadline 31 December 2026

The final core documentation obligation is the preparation of the Master File (group transfer pricing documentation).

For taxpayers with a calendar-year tax period, the deadline for preparing the Master File for 2025 is 31 December 2026, i.e. the end of the twelfth month following the end of the tax year.

This obligation applies to entities that:

• are required to prepare Local File documentation,
• belong to a group preparing consolidated financial statements under full or proportional consolidation,
• belong to a group whose consolidated revenue in the previous financial year exceeded PLN 200,000,000 (or its equivalent).

Can a Master File prepared by the group headquarters be used?

A Polish taxpayer may use group documentation prepared by the parent or any othercompany group company.

However, the documentation must comply with Polish regulatory requirements. If the foreign Master File does not include all mandatory information, a supplementary document or local addendum may be required.

The Master File may be prepared in English, although the tax authority may request a Polish translation.

How to prepare for transfer pricing obligations

Transfer pricing documentation work should begin well before October. The following steps should be taken first:

1. identify all related parties (within the meaning of Articles 11a of the CIT Act and 23m of the PIT Act),
2. collect data on transactions carried out in 2025,
3. group homogeneous transactions,
4. verify documentation thresholds,
5. assess eligibility for exemptions,
6. review the relevance of existing transfer pricing analyses,
7. reconcile intra-group financial data with accounting records and financial statements,
8. verify whether a Master File is required .

This approach reduces the risk of discrepancies between the Local File, the TPR-C form and the Master File.

Need support with transfer pricing?

Transfer pricing obligations require not only timely action, but also proper assessment of documentation and reporting requirements. We assist businesses in preparing Local Files and Master Files, transfer pricing analyses, and TPR forms. We also support threshold assessments, evaluation of available exemptions, and preparation for tax audits in the area of transfer pricing.

Contact our team if you want to ensure your transfer pricing obligations have been properly complied with or require support in preparing your 2025 documentation: https://www.mddp.pl/transfer-pricing/#formularz