Transfer pricing for 2023 – obligations and key deadlines

Transfer pricing - key deadlines

The Q4 of the year marks the arrival of transfer pricing obligations. We therefore remind you of the key deadlines:

• Preparation of basic documentation (Local file): by the end of the 10th month after the end of the tax year.
• Submission of TPR-C return: by the end of the 11th month after the end of the tax year.
• Preparation of group file (Master file): by the end of the 12th month after the end of the tax year.

TPR-C declaration - new requirements since 2023

Since 2023, the TPR-C declaration can only be signed by:

• a designated board member with a qualified electronic signature or
• an attorney who is a lawyer, legal adviser, tax adviser or auditor.

The person signing the declaration must have a UPL-1 power of attorney registered with the tax office in order to sign the declaration electronically.

Transfer pricing reporting - our recommendations

With the transfer pricing reporting deadline approaching, it is an excellent time to review your documentation obligations and start working on appropriate documentation. We recommend not postponing this obligation until the last moment, especially in the context of the new rules on signing of TPR-C declarations.

Transfer prices - how can we help?

Crowe experts provide assistance with transfer pricing documentation obligations. Our support includes, but is not limited to:

• Preparing comprehensive transfer pricing documentation,
• Adapting existing transfer pricing documentation to Polish requirements,
• Developing and implementing transfer pricing policies,
• Drafting and submitting TPR forms.

See our offer: Transfer pricing in Poland