Transfer Pricing in Poland
Ukrainian diligence to protect against potential KAS fines.
We prepare TP reporting (Local File, Master File, Benchmarking, TPR-C / TPR-P report) that will withstand the strictest audits by the Polish tax authorities and protect management from personal liability under the KKS.
● 2000+ successful TP projects.
● A team of experienced analysts (international certification in finance).
● Responses to tax authority inquiries.
● Assistance with the submission of TPR-C / TPR-P reports, including the report in XML format.
● Support throughout the statute of limitations period.
Transfer Pricing in Poland
Expert protection of your business at the intersection of two jurisdictions
Have you scaled your business and opened a subsidiary in Poland? Cross-border transactions between related parties are under the strict scrutiny of the Polish National Revenue Administration (KAS).
Polish transfer pricing legislation (Ceny transferowe) is one of the most formalized in Europe. The submission of a detailed electronic TPR-C / TPR-P form allows KAS to automatically detect profitability deviations, while the Fiscal Penal Code (KKS) provides for the personal criminal liability of management and multi-million fines.
Компанія Ardenta ensures the preparation of flawless documentation that harmonizes the requirements of both jurisdictions and withstands the strictest automated audits.
Our Approach
Harmonization of approaches in two jurisdictions and in-depth analytics
We do not merely prepare reports; we ensure the comprehensive security of the transaction on both sides of the border — for the parent and subsidiary companies, or otherwise related enterprises in Ukraine and Poland.
- Visibility of both sides of the transaction: We perfectly know the requirements of the Ukrainian State Tax Service (STS) and the harsh realities of the Polish KAS. This allows us to organize TP documentation in a way that avoids the risks of double taxation and claims from the regulatory authorities of both states.
- Comprehensive assessment of alternative economic models: To minimize tax risks, we create several parallel calculation models selecting different comparable transactions and grouping approaches. You receive options with a clear description of risks and make an informed decision.
- Complex data sets: We apply regression models for situations where the number of deliveries is measured in thousands, and the goods are not identical. We analyze exchange-traded commodities (agricultural products, metals, fuel), taking into account local regulatory requirements.
- Professional databases: We use the exact same tools as European tax authorities — Amadeus/Orbis for finding comparable companies, Royalty Range for royalties, CBONDS for loans, and Import Genius for analyzing customs statistics.
- The vast majority of economic analysis is carried out using priority methods: In Poland, there are no direct regulatory requirements regarding the prioritization of methods. Instead, local practice refers to the OECD Guidelines. The use of priority methods based on internal comparable transactions protects the business from the possibility of the regulatory authority easily questioning the results of the economic analysis.
Full Package of TP Services in Poland
The TP landscape in Poland differs significantly from local requirements in Ukraine.
Description of transfer pricing regulatory requirements in Poland
All documentation is prepared in accordance with the recommendations of the OECD Guidelines and Polish regulatory requirements (Art. 11 ustawy o CIT, Rozporządzenie Ministra Finansów z dnia 21.12.2018 r. w sprawie cen transferowych w zakresie podatku dochodowego od osób prawnych, and others). The obligation to prepare local TP documentation and submit the TPR-C / TPR-P report arises when exceeding the thresholds: PLN 10 million (goods/finance) or PLN 2 million (services).
| Product | Service Description |
| Master File (Dokumentacja grupowa) | Global documentation for companies belonging to large multinational groups. |
| Master File (Dokumentacja grupowa) | Глобальна документація для компаній, що входять до великих міжнародних груп. |
| Benchmarking (Analiza porównawcza) | Economic research to confirm the market nature of prices (the "arm's length" principle). |
| TPR-C / TPR-P Report | The most complex electronic report for KAS. We guarantee the mathematical accuracy of the data that will be analyzed by tax authority algorithms. |
Expertise Backed by Numbers and Facts
We take responsibility for the most complex stages — from initial analysis to support during regulatory audits and defense representation in court.
- Scale of Practice: Over 2,000 successfully implemented projects involving the preparation of TP documentation and economic analysis.
- International Qualification: The company's analysts are highly qualified, possess extensive experience, and work according to the highest global financial standards (international certification in finance), which ensures the appropriate level of economic analysis preparation.
- Professional Support: We provide support throughout the entire process of interacting with KAS within the TP framework, including report submission, responding to inquiries, and, if necessary, preparing a voluntary disclosure (czynny żal), etc.
Protect your business in Poland from KKS fines.
Order an audit of the presence of reportable controlled transactions, or a free initial consultation from Ardenta's experts.
If you require diagnostics regarding the presence of controlled transactions / transactions with low-tax jurisdictions that are subject to reporting in Poland, please provide the following documents regarding the Polish taxpayer:
- 1. Register of counterparties by types of transactions, indicating the types of transactions and the total transaction amount for the year (analogous to the "account turnover" report in Ukraine for accounts 362, 632) for counterparties in the following categories:
- 1.1. Related parties (residents and non-residents)
- 1.2. Unrelated non-resident parties (this can be filtered by low-tax jurisdictions defined by the Regulation of the Minister of Finance of March 28, 2019, on determining countries and territories applying harmful tax competition in the field of corporate income tax).
- 2. A comment on whether the related parties (from paragraph 1.1. above) belong to a tax capital group with the Polish taxpayer.
- 3. Financial statements of the company for the 2 years preceding the reporting year.
- 4. Average annual number of employees for the 2 years preceding the reporting year (the number of employees is not recalculated into full-time equivalents / FTE).
Attention!!
In Poland, all transactions with related parties are recognized as controlled, and the obligation to report them arises when the value thresholds for the annual transaction amount are reached. Furthermore, when determining the transaction amount, the total sum of invoices, payments, or the contract value is considered, regardless of the potential impact on the financial result (including, for instance, the principal amount of a granted loan). Therefore, upon identifying specific transactions as controlled or detecting transactions with low-tax jurisdictions, we will additionally request a register of invoices, payment records, or the texts of the agreements.
WHY CHOOSE US?
1,500
Number of prepared TP documentation sets and price justifications
200+
Number of industries
70
Number of tax audits or requests for TP documentation and price justifications by STS specialists
98%
Percentage of satisfied clients
Always on time
Number of industries
24/7 availability
