Transfer pricing in Poland: documentation thresholds and group obligations

Reviewed: 13 October 2026 · Polish law and taxation

A transfer pricing review should produce a clear decision for each transaction: prepare a local file, apply a documented exemption or assess a separate reporting requirement. A list of annual balances with group companies cannot provide that answer on its own. The analysis depends on related-party status, economic characteristics and transaction value. This article concerns a Polish company subject to corporate income tax, known as CIT.

Define the scope before adding the numbers

Confirm the tax year and the relevant related parties, including ownership changes and actual influence over business decisions. An ownership chart is a starting point, but the rules cover more than straightforward shareholdings. Identify the dealings that actually occurred: goods, services, loans, guarantees and other economic arrangements.

Give each transaction type a description that someone outside accounting can understand. A ledger account labelled “group services” may contain economically different activities. Conversely, several contracts with different group companies may form a single homogeneous transaction. The grouping needs a reasoned assessment rather than a convenient spreadsheet layout.

Have the commercial owner confirm the description.

Apply the correct threshold and valuation rule

The basic local-file thresholds are PLN 10 million for goods and financial transactions, and PLN 2 million for services and other transactions. They apply to a homogeneous controlled transaction, separately on the cost and revenue sides. The number of invoices or counterparties does not determine whether transactions are separate. See Articles 11k–11l of the Polish CIT Act.

Not every value comes from adding invoices. Loan capital and the guaranteed amount are relevant to the respective financial arrangements. Currency conversion and the treatment of VAT, including non-deductible VAT, also require attention. Transactions involving tax-haven entities have separate rules and lower thresholds, so flag them early instead of applying the standard figures indiscriminately.

Illustrative example: two contracts below PLN 2 million

A Polish company purchases comparable support services from two related parties. Their correctly determined documentation values are PLN 1.4 million and PLN 1.2 million. Each contract, viewed alone, sits below the services threshold.

If the analysis establishes a homogeneous transaction, the aggregate value is PLN 2.6 million and exceeds that threshold. The example assumes neither amount is excluded under Article 11n. The opposite shortcut would also be unreliable: buying every service from one group company does not automatically make those services homogeneous. Preserve the reason for the grouping and the source calculations so that the conclusion can be checked later.

Review exemptions and reporting separately

Before the final threshold comparison, exclude transactions covered by Article 11n as required by Article 11l(3). A domestic exemption has conditions applying to the parties; a Polish address for both does not settle the issue. Record the legal basis and evidence for the relevant year. Last year's conclusion needs review if profitability, tax status or the transaction model has changed.

Assess TPR reporting and group documentation separately. Some local-file exemptions still leave a TPR reporting obligation. Under the basic timetable, the local file is due by the end of the tenth month after the tax year, and TPR by the end of the eleventh. Set the actual calendar dates using the company's tax year and applicable deadline rules.

Domestic exemption: check every party

Article 11n(1) requires each party to a domestic transaction to satisfy the relevant conditions jointly: no entity exemption under Article 6, no special-economic-zone or PSI exemption under Article 17(1)(34) and (34a), and no tax loss. For losses, examine the relevant income source and the position applicable to the facts rather than comparing only accounting results. Obtain annual confirmations from all parties. Then assess TPR separately: exemption from documentation does not automatically exempt the information return.

Classification checklist and next step

• Confirm the tax year and complete related-party map.
• Describe the actual economic subject of each transaction group.
• Explain homogeneity and separate the cost and revenue sides.
• Check valuation, currencies, VAT and financing-specific rules.
• Document each exemption and the supporting evidence.
• Assess local-file, TPR and master-file requirements individually.

The result should be a classification register with data owners and unresolved questions. TLP's transfer pricing service can help review the grouping and obligations of the Polish company. Start with the transaction categories and tax year so the review can target the decisions that determine the documentation scope.