The consistent development of the Polish economy, which has been noted for many years, and, above all, an increasing number of companies that belong to capital groups, account for the fact that transfer pricing is not merely a theoretical question, but instead it is a factor that should be taken into consideration each day when transactions are made with related entities.
The changing regulations about transfer pricing come to taxpayers as a challenge, since they must correctly verify the requirement of documentation. Taxpayers may find it extremely difficult to describe all the components in the local and master files as required by the laws. This is especially true, given the fact that the scope of the local file and the master file as prescribed by the regulations applying from 2017 was much more detailed than OECD guidelines in this respect.
This section presents how to determine the requirement of documentation and the scope of such requirement in accordance with the regulations that apply from 2017 and from 2019.