This is a thought leadership article by PrimeGlobal member firm ATA Finance which looks at the extended deadlines for the preparation of transfer-pricing documentation for 2019 in Poland.

Related parties have received more time to comply with their obligations connected with transfer-pricing documentation. According to Shield 4.0, the deadline for the submission of a transfer pricing report (TPR) and a statement of preparation of local transfer-pricing documentation has been extended: 

1) until December 31, 2020 – where that deadline expires between March 31, 2020 and September 30, 2020; 

2) by 3 months – where that deadline expires between October 1, 2020 and January 31, 2021.

In the case of a large group of taxpayers whose financial year coincides with the calendar year, those time-limits will therefore expire on 31 December rather than 30 September. What is more, the provisions also provide for an extension of the deadline for preparing the group documentation (the so-called Master file) until the end of the third month from the day following the day on which the deadline for submitting the statement expired.

Please be reminded that since January 1, 2019 related parties have been obliged to prepare local transfer-pricing documentation (the so-called Local file) for a controlled transaction of a uniform nature, whose net value will exceed in the financial year:

- PLN 10 000 000 – in case of commodity and financial transactions;

- PLN 2 000 000 – in case of a service or another transaction.

However, related parties consolidated using the full or proportional method which are obliged to prepare local transfer-pricing documentation, enclose a group transfer-pricing documentation if they belong to a group of related entities:

- for which a consolidated financial statement is being prepared;

- whose consolidated revenue exceeded in the previous financial year PLN 200,000,000 or its equivalent.

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ATA Finance

ATA Finance provides comprehensive services for entrepreneurs and investors. In Poland, we operate through our offices in Warsaw and in Katowice. We employ around 40 experts. Our team, made up of auditors, tax advisors and certified accountants, executes interdisciplinary projects, such as financial and tax reviews, company valuations, financial and tax optimization, implementation of international accounting standards. Furthermore, we offer domiciliation services including subleasing an office address, handling incoming mail and the use of conference rooms/facilities. ATA Finance works also on international projects along with our partners from PrimeGlobal. Among our clients, there are national and foreign companies and organizations from various sectors, including finance, energy, construction, production, commerce and real estate.

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