RSM Poland


Extended Transfer Pricing Documentation Deadlines for 2020

Taxpayers will most certainly be happy to learn that on 8 April 2021 the President signed the Act Amending the Excise Tax Act and Certain Other Acts, which extends the deadline for transfer pricing reporting.

In line with the adopted solutions, the deadline for submitting transfer pricing information and a statement on Local File preparation has been extended:

  • until 30 September 2021, where this deadline expires between 1 February 2021 and 30 June 2021;
  • by 3 months, where this deadline expires between 1 July 2021 and 31 December 2021.

This means that taxpayers whose tax year overlaps with the calendar year will be required to comply with their transfer pricing reporting obligations by the end of December 2021.

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In connection with the aforementioned changes, the deadline for attaching a Master File to the Local File has also been extended. This obligation must be fulfilled by the end of the third month following the day in which the deadline for submitting the statement on Local File preparation has expired.

Taxpayers should take the extra time they were given to prepare their transfer pricing documentation, in particular to analyse and maybe modify their benchmarking studies in the face of the economic crisis caused by the COVID-19 pandemic. Let me remind you that in accordance with Article 11r of the Corporate Income Tax Act: “a benchmarking study and compliance analysis shall be updated at east every 3 years, unless the economic environment has changed to a degree that significantly affects the analysis and thus justifies an update in the year in which the change has occurred”. The upheaval in markets and economies caused by the pandemic has had an effect on the ‘economic environment’ in most industries; hence it will make it necessary to update benchmarking studies.

Should you have questions or need to discuss the topic further, we encourage you to contact our expert, Tomaszem BEGER:


phone: +48 61 8515 766

fax +48 61 8515 786

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