In 2026, transfer pricing remains one of the most demanding areas of Polish tax compliance. What matters more than ever is the quality and consistency of financial data reported in the Transfer Pricing Information form (TPR), Country-by-Country Reporting (CbC) and public CbC reporting (PCbCR) — and how well those figures tie back to your accounting books, statutory financial statements and transfer pricing documentation.
For many companies, this means treating TP (transfer pricing) as a repeatable, year-round process: a core part of tax risk management and, for large groups, also reputational risk management.
Why 2026 is particularly important for transfer pricing
TP reporting is no longer just compliance. In Poland, the tax authorities (National Revenue Administration – Krajowa Administracja Skarbowa (KAS)) use TPR data as an analytical and comparative dataset across taxpayers and across years. Even small inconsistencies can trigger verification activities or a tax audit.
At the same time, 2026 increases the pressure on tax transparency for large capital groups. PCbCR requires that publicly disclosed information aligns with internal tax and finance data used in reports such as TPR and CbC.
Who transfer pricing rules apply to — and what most often creates risk
Polish transfer pricing obligations primarily apply to entities entering into controlled transactions with related parties. In practice, risk most often appears when:
- related-party links are identified incorrectly (e.g., indirect, personal or de facto links),
- transactions are misclassified (TPR category does not reflect reality),
- transaction outcomes (margins, EBIT, mark-ups) don’t reconcile to the books and financial statements,
- there is no clear business rationale — especially for intangible services,
- the reporting workflow is not integrated with the year-end close.
Documentation thresholds: when does the Local File obligation arise?
A key step is determining whether you exceeded documentation thresholds (which differ depending on the transaction type). From an operational perspective, it helps to have a standing procedure covering:
- transaction identification,
- value calculation for threshold testing,
- decision on documentation scope,
- verification of any special obligations (e.g., “tax haven” exposure, restructurings, financial settlements).
Transactions involving “tax haven” jurisdictions
Transactions with entities that have their registered office, management or residence in jurisdictions regarded as applying harmful tax competition require particular care. In Poland, documentation obligations may apply not only to related-party transactions but also to dealings with unrelated entities — typically with lower thresholds and higher expectations around economic substance and evidence quality.
Transfer pricing documentation in 2026: the elements that must reconcile
In 2026, the focus shifts strongly to data integrity and consistency. The most practical approach is process-based:
1) Transaction map and source data inventory
- parties, values, currencies, periods,
- agreements and settlement rules,
- allocation keys (if used),
- data sources: ERP, accounting ledgers, controlling systems.
2) Method selection and evidence of arm’s length outcomes
Your transfer pricing method should be properly justified and applied consistently. In many areas, benchmarking (comparability analysis) becomes essential because it supports the margin and profitability levels reported in TPR.
3) Reconciliation with accounting books and statutory financial statements
The most common issue is misalignment between:
- group controlling data,
- accounting books,
- statutory financial statements,
- values reported in TPR.
4) Business rationale and documented decision-making process
This is especially critical for:
- intangible services (management, IT, marketing, licensing),
- restructurings (transfer of functions, assets, risks),
- transfer pricing adjustments (bringing results to an arm’s length level).
TPR in 2026: schemas, forms and key changes
TPR as an analytical tool
TPR is designed to let tax authorities quickly assess a taxpayer’s risk profile. The dataset is detailed enough that even minor inconsistencies can trigger follow-up questions.
TPR-C(6) and TPR-P(6): reporting under updated schemas
Poland’s Ministry of Finance has published the TPR schema variant 6 for TPR-C and TPR-P (including TPR-C(6) / TPR-P(6)). For finance and tax teams, that typically means verifying whether systems and reporting tools can generate data in the required structure and whether responsible staff understand the new fields and logic.
What changes in practice (high-impact areas)
In operational terms, 2026 reporting may involve, among others:
- indicating the accounting standard used (e.g., Polish Accounting Act rules vs IFRS),
- updates to financial indicators and naming to reflect the current P&L structure,
- the possibility to report PKD codes (Polish Classification of Activities) in the relevant classification variant.
Interactive forms vs. your own tools
Interactive forms can be used as a support tool. Other solutions (including in-house tools) are acceptable — provided they generate files compliant with the required XML structure.
Deadlines: how to interpret them operationally
For most taxpayers in Poland, deadlines are structured as follows:
- Local File: by the end of the 10th month after the tax year-end,
- TPR (including the statement made within the form): by the end of the 11th month after the tax year-end,
- Master File: by the end of the 12th month after the tax year-end.
In practice, this means transfer pricing must be coordinated with the year-end close, financial audit, and controlling timelines.
Signing TPR and the role of an authorised representative
The TPR signature should be preceded by a formal review of the data and assumptions. In practice, TPR can be signed and submitted by a professional authorised representative (subject to formal requirements). This can streamline the reporting process — but it does not replace internal data quality controls and documented sign-off on key assumptions.
TPR vs. ORD-U: parallel obligations that are often missed
ORD-U and TPR are separate Polish reporting obligations with different legal bases and goals. As a rule, taxpayers required to file TPR may benefit from an ORD-U exemption — however, this exemption does not apply in certain cases (including specific exposures involving jurisdictions applying harmful tax competition). That is why ORD-U must be verified independently of TPR each year.
Two practical takeaways:
- ORD-U thresholds and reportable contract scope may differ from TPR,
- filing deadlines are similar, which often leads to the mistaken assumption that it’s “one process”.
From an organisational standpoint, a simple control works well: treat “TPR + ORD-U” as two separate calendar items.
IFT and withholding tax: why this overlaps with transfer pricing
Payments to non-residents (e.g., interest, dividends, selected intangible services) can trigger Polish withholding tax (WHT) obligations and IFT reporting. The same payment streams often appear in transfer pricing documentation. Misalignment between WHT/IFT and TP datasets can increase the likelihood of questions from authorities — so it’s worth linking these processes at the data and internal control level.
APA and APA-C reporting: maintaining protection requires data discipline
If your company has an Advance Pricing Agreement (APA), reporting on APA implementation (APA-C/APA-P) should be treated as part of maintaining that protection. Key consistency checks should cover:
- Local File documentation,
- TPR reporting,
- actual financial results.
CbC and PCbCR in 2026: data consistency and reputational risk
CbCR: group obligations
CbC applies to the largest groups (generally above the revenue threshold). In practice, the crucial areas are:
- deadlines (report and notification),
- correct role assignment in the group (who reports, who notifies),
- consistency with local reports and TP documentation.
PCbCR: public transparency
PCbCR is different from “classic” CbCR, but relies on the same source data. For many groups, 2026 brings a real need to align publicly disclosed PCbCR information with statutory, tax and TP documentation data. For calendar-year groups, the first public report commonly covers fiscal year 2025 and is expected to be published by the end of 2026.
Possible simplifications in 2026: what to expect operationally
There may be discussions in Poland about simplifying transfer pricing reporting (e.g., reducing formalities for smaller entities or adjusting the signing/submission process for TPR). The most practical conclusion remains: design your TP process to be resilient to technical changes (forms/schemas) and built on reliable data and documented assumptions.
2026 priorities: how CFOs and management can reduce transfer pricing risk
Recommended priorities for CFOs and management teams include:
- reviewing the profitability model (including routine entity models),
- aligning and documenting margin and EBIT calculation logic,
- strengthening the quality and reconciliation of data reported in TPR to the accounting books,
- organising documentation for intangible services (proof of performance, benefit test, allocation rules),
- preparing benchmarks earlier (not at the final stage of the year-end close),
- implementing a consistent timeline: year-end close → audit → transfer pricing → TPR → group reporting.
If your goal is to reduce risk and structure reporting, a practical approach is to combine transfer pricing documentation work with a robust reconciliation of financial data. This is where tax advisory in Poland can support your internal teams.
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