Transfer Pricing in Poland – Rödl & Partner Launches TP Scan to Help Businesses Prepare for Deadlines

Transfer pricing rules in Poland apply to transactions between associated entities and require that they be conducted under arm’s length conditions. To help companies meet these obligations, Rödl & Partner has introduced TP Scan, a tool that identifies whether a transaction needs to be documented, pinpoints possible exemptions, streamlines the collection of necessary information, and provides procedures for handling audits.

“TP Scan gives companies the structure, clarity, and confidence they need to navigate increasingly detailed tax audits,” says Dominika Tyczka-Szyda, a  tax adviser and a partner at Rödl & Partner. The tool is available through Rödl & Partner Poland. More information and contact details can be found at roedl.pl​.

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Transfer Pricing in Poland – How TP Scan Helps Businesses Stay Compliant

Polish companies are preparing to meet one of the most complex tax compliance requirements: transfer pricing documentation. Increasingly detailed audits and high penalties for non-compliance have elevated the issue from a finance department task to a top priority for management boards. Deadlines are approaching fast for companies whose financial year matches the calendar year. They must prepare their 2024 transfer pricing documentation by 31 October 2025 and are required to submit the TPR-C form to tax authorities one month later, by 30 November, a step that can only be completed once the documentation is ready. While these dates may seem distant, experience shows that last-minute preparation often leads to unnecessary stress and increased risk of errors.

Transfer pricing rules in Poland apply to transactions between associated entities, such as companies from the same corporate group. The law requires these transactions to be carried out under arm's length conditions, meaning they must reflect the terms that would apply between independent entities. To prove compliance, companies must prepare detailed documentation, conduct benchmarking studies, and report their data to tax authorities. Missing the above deadlines or failing to meet the above requirements can lead to penalties to the tune of millions of złoty, personally affecting management board members.

“Transfer pricing compliance is now one of the most significant areas in international taxation in Poland. Tax audits are increasingly detailed, and the rules are precise. That's why tools that help companies identify obligations and arrange documentation are essential," says Dominika Tyczka-Szyda, a tax adviser and a Partner at Rödl & Partner Poland. To help companies navigate these challenges, Rödl & Partner Poland's tax team has developed TP Scan, a proprietary tool that guides businesses through the verification and preparation process for transfer pricing compliance. TP Scan assesses whether a company is subject to transfer pricing documentation requirements and identifies potential exemptions. It also streamlines the gathering of necessary materials by providing a clear checklist and guidance on where to obtain them, from accounting records and legal contracts to ERP systems. The tool further offers procedures for responding effectively to tax audit results; this feature is included in the package.

According to Dominika Tyczka-Szyda, TP Scan​ offers more than just legal compliance. It improves internal processes, reduces the risk of errors and omissions, and ensures that companies are ready for potential tax audits. For international groups, it enhances tax security in cross-border operations and provides a structured, well-organized approach to documentation. “From an adviser's perspective, a well-prepared company goes through a transfer pricing audit calmly and efficiently. TP Scan provides that peace of mind," she says.​