TRANSFER PRICING REPORTING (TPR)

Are you part of a capital group and conducting business in multiple countries, including Poland? Are you planning to expand your business into Polish market? Are you wondering how to meet transfer pricing requirements?

Our expert team is here to streamline a process of transfer pricing compliance. As a comprehensive tax advisor, we can offer extensive services in the area of transfer pricing (Local file and Master file documentation, Transfer Pricing Analysis, TPR-C reporting and CBC reporting etc.).

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TPR-C

The TPR information constitutes a detailed report submitted to tax offices by taxpayers engaged in transactions with related parties or / and tax havens exceeding statutory thresholds within the reported tax year. The obligation of TPR submission pertains to:

• transactions with related parties covered in the local TP documentation,
• transactions with entities from tax havens covered in the local TP documentation,
• domestic transactions with related parties exempted from local TP documentation (as defined in Polish CIT Act).

The intention of the legislator is to obtain general information on the taxpayer’s financial results and applied methods of transfer pricing verification. In particular, TPR provides information if the result on a documented transaction is covered within the arm’s length range determined by TP analysis. Therefore, tax authorities use the TPR form to select taxpayers for transfer pricing audits.

Key Compliance Deadlines & Requirements

📌 Deadline: TPR is submitted in the electronic form to the relevant tax office by the end of 11^th month following the end of the reported tax year.

📌 General rules:

As a rule, the person authorized to sign and submit the TPR-C information is a designated member of the management board.

The complete procedure of TPR submission might seem complicated as it involves:

✅ UPL-1 power of attorney: UPL-1 should be granted and submitted to the Tax Office for the person designated to sign and submit the TPR-C information. In practice, it may happen that the same management board member who will sign and submit the TPR-C information may grant himself a power of attorney (provided he is authorized to represent the entity independently).

✅ PESEL number: To complete the UPL-1 power of attorney, the PESEL identification number of the authorized person who will later sign the TPR-C information is required. The PESEL number must also be embedded into the qualified electronic signature used to sign the TPR-C information.

✅ Signing: The TPR-C information is signed using a qualified electronic signature, which is certified by an entity designated by any European Union Member State.

✅ Submission: The TPR-C information is submitted to the tax authorities in XML format.

How can we help?

Crido may assist in preparation of the TPR-C forms:

✅ preparing files with input data for transfer pricing information, including the calculation of overall profitability indicators, proposing appropriate grouping and description of transactions in the forms, as well as presenting financial indicators in relation to the transfer pricing analyses held by the Client;

✅ preparing TPR-C forms in a format that, once signed, can be submitted to the relevant tax office (XML files with visualizations in PDF format).

The scope of TP services may also include preparation of powers of attorney (UPL-1) and support in obtaining PESEL number.

Why choose CRIDO?

Extensive Experience in preparation of TPR: We have successfully assisted numerous clients across various industries in preparing TPR-C and TPR-P reports, ensuring full compliance with Polish transfer pricing regulations. Our team stays ahead of evolving tax authority expectations and interpretative practices to minimize risks for your business.

Automated & Streamlined TPR Reporting: TPR forms are prepared by Crido in a two-stage process using Compass TPR tool enabling automatization and visualisation of the reported data for Client’s comfort. Additionally, clients have the option to purchase our proprietary Compass TPR tool, allowing them to independently prepare TPR forms with ease.

Comprehensive Support: Our experts support you throughout the entire TPR process, including the preparation of the UPL-1 power of attorney and assistance in obtaining a PESEL identification number. We are also happy to provide consultations and guidance on the entire TPR submission process.

Proactive Updates & Regulatory Insights: Through active participation in legislative processes, we keep our clients informed about the latest legislative developments and interpretative changes affecting TPR reporting. This allows for a proactive approach in adapting to regulatory requirements and mitigating potential risks before they arise.

Contact us today to learn more about how we can assist you to achieve your business goals involving Poland in a safe way.