In December 2025, amended regulations on transfer pricing information for corporate and personal income tax (TPR Regulations) were published in the Journal of Laws. While the changes may seem minor, they have a real impact on how transfer pricing is reported locally and on the scope of data provided through transfer pricing information (TPR Forms) starting with the 2025 tax year.

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Key changes introduced

The amendments align TPR Forms with recent changes to the Accounting Act and introduce several updates:

  • Updated financial indicator formulas – names of calculation formulas have been revised to match the updated terminology used in the profit and loss account. This affects the entity’s overall profitability ratios (operating margin and gross profit margin) and ratios used in transfer pricing analyses.
  • Obligation to indicate the accounting standard – a new field requires entities to specify whether financial statements were prepared under the Polish Accounting Act, IFRS, or not prepared at all.
  • Editorial changes and clarification of terminology – the name of the controlled transaction category with code 3005 has been updated ("Restructuring - transfer of intangible assets and rights to intangible assets" instead of "Restructuring - transfer of intangible assets and rights to intangible assets and legal rights") and the content of the annex to the TPR Regulations has been reorganized.

New reporting templates

Following the amended TPR Regulations, new logical structures for TPR Forms have been published on the Ministry of Finance website, as well as in the official repository of electronic document templates (TPR-C(6), TPR-P(6)). Interactive online TPR Forms compliant with the new templates will be available soon.

Effective date and deadlines

The amended regulations apply to TPR Forms submitted for tax years beginning after December 31, 2024. For most entities, the deadline to submit TPR Forms for 2025 is end of November 2026. However, entities with shortened tax years (e.g., due to mergers or liquidation) may need to comply earlier.

Significance of the changes for taxpayers

Even if your group prepares transfer pricing documentation and benchmarks centrally, Polish law imposes a separate local transfer pricing reporting obligation. TPR Forms must be submitted electronically to the Polish tax authorities. Failure to comply may result in penalties, so it is crucial to ensure these forms are completed correctly and in line with the latest requirements.

In practice, the transfer pricing reporting process will not change significantly, but it is worth being aware of the new requirements in order to avoid mistakes when completing the TPR Forms for 2025.

Feel free to contact us if you need support in fulfilling this local obligation or ensuring that your organization has taken into account the amended transfer pricing reporting rules.