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Centralised transfer pricing documentation prepared at the capital group level, presenting the transactions carried out among the entities composing it.

Holding such documentation in relation to the legal status prior to 1 January 2017 was not mandatory and did not release the taxpayer from the preparation of the TP report at the so-called local level (local file), which took into account the requirements provided for in Polish regulations.

Starting from 1 January 2017, master file has been a mandatory element of the TP report for taxpayers whose accounting revenue (expenses) exceeded EUR 20 million. This document includes, inter alia, the specification of the related entity that prepared the TP report, the organisational structure of the group and a description of the principles of determination of transaction prices (transaction prices policy) applied by the group of related entities.