Poland: Transfer pricing measures in “Polish Deal” legislation

Measures in the bill, assuming it is signed by the president and enacted, will generally be effective 1 January 2022.

Measures in the bill will generally be effective 1 January 2022.

The Polish Parliament on 29 October 2021 passed a bill—referred to the “Polish Deal”—amending the income tax laws and including transfer pricing-related measures.

The measures in the bill, assuming it is signed by the president and enacted, will generally be effective 1 January 2022.

As introduced, the bill included several measures regarding transfer pricing to:

  • Simplify and clarify the requirements for signing the statement regarding transfer pricing documentation
  • Provide new exemptions from transfer pricing documentation obligations
  • Extend the deadline for submitting transfer pricing documentation
  • Amend the rules for making transfer pricing adjustments
  • Revise the related tax penalty regime

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The version of the bill as passed by the Parliament also included a measure for the extension of the deadline for the submission of the Local file to 14 days (from seven days) from the date of request by the tax authority and also clarified certain financial safe harbor provisions and simplified rules for making transfer price adjustments.

Read a November 2021 report prepared by the KPMG member firm in Poland


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