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Poland: Transfer pricing legislative changes 2021


published on 19 April 2021


New transfer pricing regulations which extend documentation obligations for transactions with tax havens to the disadvantage of taxpayers came into force on 1 January 2021.
Changes to the regulations include:

  • new obligation to prepare transfer pricing documentation for transactions in which the beneficial owner is an entity other than the taxpayer's contractor and has its place of residence, registered office or management in the territory or in a country applying harmful tax competition (the so-called tax haven). The threshold for such transactions is 500,000 zloty;
  • extended obligation to prepare documentation to include all transactions performed by a taxpayer directly with an entity from a tax haven. The threshold remains unchanged – i.e. 100,000 zloty;
  • extended content of the local file for transactions with a tax haven to include economic justification, including, among others, expected economic benefits arising from the execution of such transactions.


Favourable changes to transfer pricing regulations include transfer pricing adjustments and the rules of exemption from the documentation obligation for transactions between domestic entities.


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