TPR Reporting in 2024 – key information

1. What is the TPR Information?

The TPR Information (Transfer Pricing Reporting) is a key tool supporting financial transparency and tax risk assessment. It covers detailed information on transactions carried out between related parties, as well as between taxpayers and counterparties established in countries regarded as applying harmful tax competition (so-called tax havens).

2. Who is required to file it and when?

The obligation to submit TPR Information applies to entities carrying out controlled transactions with related parties or transactions with entities from countries applying harmful tax competition.

The TPR Information is submitted electronically to the competent head of the tax office.

Filing deadline:
For the 2024 tax year (if it coincides with the calendar year), the TPR Information must be submitted by 30 November 2025.
Pursuant to Article 11t(1) of the CIT Act, the TPR Information is submitted within 11 months of the end of the tax year.

3. Scope of the information

The TPR form must include, among others:

• indication of the authority to which it is submitted, the purpose of submitting the information and the period it relates to,
• identification data of the entity,
• the entity’s general financial information,
• data on related parties and controlled transactions,
• information on the transfer prices applied and the methods used to verify them,
• additional information or explanations relating to the above data,
• the entity’s statement that the local transfer pricing documentation has been prepared in accordance with the actual state of affairs and that the transfer prices covered by this documentation are determined on arm’s length terms – i.e. on the terms that would have been agreed between unrelated parties.

4. What to keep in mind in 2024

On 31 October 2025, the Ministry of Finance published the sixth edition of the “Transfer Pricing Information – Questions and Answers”, which contains a number of new clarifications and supporting materials for taxpayers.

This publication is an updated set of practical answers to questions concerning, among other things:

• how to convert transaction values in foreign currencies,
• reporting multi-year transactions,
• rules for recognising transfer pricing adjustments,
• and the interpretation of documentation thresholds.

The Ministry of Finance’s document is a valuable source of information for both taxpayers and advisors – it clarifies numerous doubts that arose in previous years.

The sixth edition – in addition to editorial changes – also introduces important substantive modifications. The answers to questions no. 131 and 140 have been amended, and new questions no. 137 and 153 have been added.

The common objective of these changes is to standardise the approach to converting into PLN the value of debt and interest amounts (on an accrual and cash basis) for financial transactions in foreign currencies, especially in groups of categories C and D, which also include transactions covered by the safe harbour rules.

The Ministry of Finance emphasises that the new solutions are intended to simplify reporting and improve the consistency of data submitted in TPR Information.

Importantly, taxpayers submitting TPR for 2024 may apply the rules for completing the form resulting from either the 5th or the 6th edition of the Information.

Key changes:

• amended answers to questions 131 and 140 – concerning the conversion of amounts from foreign currencies in the fields: “Value of debt”, “Amount of interest (accrual)”, “Amount of interest (cash)”;
• added questions 137 and 153, which systematise the conversion rules for financial transactions in foreign currency (including those covered by the safe harbour);
• acceptance – only for the 2024 TPR – of applying the rules arising from either the 5th or the 6th edition of the Information.

5. Significance for taxpayers

TPR reporting is of material importance:

Regulatory compliance: correct and timely filing of the TPR minimises the risk of sanctions.

Transparency: it builds credibility with authorities and business partners.

Internal analysis: TPR data helps assess the profitability and efficiency of transactions with related parties.

6. How to prepare

To ensure correct and timely TPR reporting for 2024, the following steps should be taken:

• review controlled transactions and identify those that are subject to the reporting obligation – including identifying transactions subject to the obligation to prepare local transfer pricing documentation (for transactions exceeding materiality thresholds) and those that benefit from the documentation exemption,
• verify financial data and the completeness of the local transfer pricing documentation (Local File),
• check the correctness of the methods used to verify transfer prices and the accuracy of calculations.

7. Summary

TPR reporting is not only a formal obligation, but also an important element of building financial transparency and tax compliance.

It allows better monitoring of transactions with related parties, identification of potential tax risks, and supports informed business decision-making.

Our advisors support clients throughout the TPR reporting process, ensuring compliance with the applicable regulations and the interpretative practice of the Ministry of Finance, as well as advising on optimising reporting processes and preparing transfer pricing documentation.