Changes in the Transfer Pricing Area in the Context of the Planned Amendment to the Personal Income Tax Act and the Corporate Income Tax Act

Information regarding work on a draft act amending the Personal Income Tax Act and the Corporate Income Tax Act has been published in the list of legislative and programme works of the Council of Ministers. The project has been assigned number UDER107, where the prefix DER indicates that it is a deregulatory initiative.

According to information published on the website of the Chancellery of the Prime Minister, the draft implements deregulation proposals aimed at eliminating unnecessary administrative procedures, reducing the costs of doing business, and increasing transparency while simplifying the tax system.

The draft provides for amendments to:

• the Act of 26 July 1991 on Personal Income Tax (Journal of Laws of 2025, item 163, as amended), and
• the Act of 15 February 1992 on Corporate Income Tax (Journal of Laws of 2025, item 278, as amended).

The main proposed changes in the area of transfer pricing include:

Liberalisation of the rules for signing the TPR form

The rules for signing the TPR Information return are to be relaxed. The form will be signed in accordance with the rules set out in the Tax Ordinance Act, which will allow it to be submitted by an authorised representative acting on behalf of the entity.

Incorporation of the TP statement into transfer pricing documentation

The statement confirming the preparation of local transfer pricing documentation will be integrated into the documentation itself. This change may simplify the reporting process and ensure greater consistency between the information presented in the documentation and the taxpayer’s formal obligations.

Changes to TPR reporting for micro and small taxpayers

Micro and small enterprises will no longer be required to report financial indicators assessing their financial condition in the TPR Information. The aim of this change is to simplify reporting obligations for this group of taxpayers.

Changes regarding transfer pricing adjustments

The proposed amendments clarify the regulations concerning transfer pricing adjustments (so-called compensating adjustments) made between domestic entities. In particular, the changes are intended to remove existing ambiguities regarding the permissibility of such adjustments between entities established in Poland.

Accordingly, the solutions envisaged in the draft are intended to reduce the administrative burden on taxpayers, which should facilitate business operations, simplify formal requirements for citizens, and improve the efficiency and effectiveness of tax authorities.

The planned date for the adoption of the draft by the Council of Ministers is the first or second quarter of 2026.