Poland TPR reporting: reconcile the form with the local file

Reviewed: 13 October 2026 · Polish law and taxation

Poland's TPR return should describe the same economic reality as the transfer pricing documentation and financial records. Differences do not always indicate an incorrect price: they can arise from data scope, indicator definitions or an omitted adjustment. A pre-signature reconciliation should make every material difference explainable. This article concerns TPR-C for a Polish company subject to corporate income tax.

Confirm the reporting period and basis

Start with the tax year, transactions in scope and the form version applicable to that period. A template saved last year may no longer fit. The Ministry of Finance transfer pricing portal provides structures, updates and reporting guidance.

Article 11t of the CIT Act requires TPR to be based on the local file where that documentation is mandatory. Where it is not required, the relevant financial statements and other documents provide the reporting basis. A documentation exemption therefore does not remove the need to validate a reportable transaction. Determine the required data and statement for the particular reporting obligation.

Reconcile four layers of information

First, check completeness. Does the TPR transaction list match the completed obligations assessment? Include exempt transactions that remain reportable. Reusing last year's list can miss new charging arrangements or financing that ended during the period.

Second, reconcile values. Each reported amount should have a source, period, conversion method and explanation of adjustments. A difference from ledger turnover may be justified, but another reviewer should be able to reproduce it. Identify which adjustments were included and why they belong to the year under review.

Third, examine the method and financial indicators. Check the tested entity, numerator, denominator and included revenue or costs. Fourth, compare the descriptions: the agreement, functional analysis, pricing explanation and form should not rely on contradictory assumptions. Record unresolved questions rather than forcing a numerical match that conceals the underlying issue.

Illustrative example: mark-up and margin differ

Assume a simplified service transaction has costs of 100 and revenue of 105. Profit is 5. The mark-up on costs is 5%, while the profit margin measured against revenue is approximately 4.76%.

Copying 5% into a field simply because the contract uses that figure may misstate the information. Establish which indicator the relevant category and method require. This example does not determine the correct reporting indicator for an actual transaction. It shows why definitions need checking alongside numbers. Equally, establish whether the calculation uses the transaction, a business segment or the company's entire activity.

A useful review file retains the formula and data selection. That makes a later question about the indicator answerable without rebuilding the calculation from memory.

Sign after the review is complete

Within its statutory scope, TPR includes a statement concerning factual accuracy of the local documentation and the arm's-length nature of the prices. Article 11t of the CIT Act also specifies signing rules. Check the proposed signatory's authority; preparing the file does not itself confer signing rights.

The signatory should receive a short note covering the review, data sources and unresolved issues. Technical acceptance and the official receipt, UPO, evidence the submission stage rather than substantive correctness. The general deadline is the end of the eleventh month after the tax year, subject to applicable deadline-calculation rules.

Signature and declaration: choose the correct variant

For exempt transactions listed in Article 11t(4), TPR has a reduced scope and omits the declaration specified there. Match the data to the reporting basis. The signature rules allow a designated member of a collective management body and an exception for an attorney-in-fact who is an advocate, legal adviser, tax adviser or statutory auditor. An ordinary accountant’s power of attorney is insufficient. Designating a board member to sign does not release the other members from responsibility for failure to file.

Final checklist and next step

• Confirm period, form version and complete transaction coverage.
• Trace each value to the accounts and explain differences.
• Review indicator definitions and calculation inputs.
• Reconcile adjustments, method and functional descriptions.
• Resolve open issues and verify signing authority.
• Retain the final return, approvals and official receipt.

TLP's transfer pricing advisory service can review this reconciliation before TPR submission. Begin with the draft return, transaction list and exceptions requiring a decision so the work addresses substantive consistency as well as completion of the form.