Documentation prepared in accordance with national regulations on transfer pricing (local documentation).

Pursuant to the regulations in force before 1 January 2017, the documentation should include the following information:

1. specification of the functions of the parties to the transaction, involved assets and assumed risk;
2. specification of the costs related to the transaction and the time limit and form of remuneration payment;
3. specification of the transaction price and the method and manner of profit calculation;
4. description of the economic strategy - only if it had an impact on the transaction price;
5. formulation of the expected benefits in connection with the performed transaction if its subjects are provisions/services of intangible nature;
6. specification of other factors - if they had impact on the price agreed between the related entities.

In relation to the transactions made from the beginning of 2017, local documentation should include:

1. description of the transactions or other events between the taxpayer (a company other than a legal person) and related entities, including:

• specification of the type and subject of such transactions or other events;
• financial data, including cash flows related to such transactions or other events;
• details identifying the related entities performing these transactions or recognising these events;
• description of the course of these transactions or other events, including the functions performed by the taxpayer (a company other than a legal person) and the related entities, balance sheet and off-balance sheet assets engaged by them, human capital and risks incurred;
• specification of the method and manner of taxpayer's income (loss) calculation with the reason for their choice, including the algorithm for the calculation of settlements concerning these transactions or other events and the manner of the calculation of the value of the settlements affecting the taxpayer's income (loss) (other shareholders of the company other than a legal person); 

 2. comparative analysis (in case of taxpayers whose accounting revenue or expenses exceed EUR 10 million);

3. description of the taxpayer's financial data;

4. information on the taxpayer, including a description of:

• the organisational structure and the management structure,
• the subject and the scope of the business,
• the pursued economic strategy, including the transfers of economically important functions, assets or risks, affecting the taxpayer's income (loss) conducted in the fiscal year or in the year preceding the fiscal year between related parties,
• the competitive environment; 

 5. documents, in particular:

• contracts, agreements concluded between related entities or other documents concerning transactions or other events, a deed of a company other than a legal person, a joint venture agreement or similar contracts/agreements, documenting the principles of granting rights to shareholders (contracting parties) to participate in the profit and to participate in losses,
• agreements on the income tax concluded with tax administrations of countries other than the Republic of Poland, concerning transactions or other events, in particular Advance Pricing Agreements (APA).

After exceeding the threshold of EUR 2 million in revenue (expenses), in addition to the obligation to prepare the local file, starting from 2017, the taxpayer is also required to submit, together with the tax return, a declaration on its preparation. This is to increase the personal liability of persons responsible for the taxpayer's tax settlements.

In case of exceeding the level of accounting revenue or expenses in the amount of EUR 10 million, the TP report must also include a comparative analysis (so-called benchmark), i.e. the analysis of data concerning independent entities or data agreed with an independent entity with the specification of the data source.

Moreover, starting from 1 January 2017, taxpayers whose level of revenue (expenses) exceeded EUR 10 million are also obliged to provide tax authorities with a simplified report on the transactions and other events taking place between related entities (so-called CIT-TP for taxpayers subject to corporate income tax and so-called PIT-TP for taxpayers subject to personal income tax).