By December 1, 2025 (for taxpayers whose tax year coincides with the calendar year), companies must submit their Transfer Pricing Report (TPR-C) for the year 2024. This obligation applies to many entities engaged in transactions with related parties, as well as to certain transactions with counterparties located in tax havens.
The essence of TPR-C report
The TPR-C form (for CIT taxpayers) is a detailed report on transfer prices and the conditions of transactions conducted between related entities.
It includes, among others:
- identification data of the taxpayer and related parties,
- financial information,
- description of controlled transactions, methods used to verify transfer prices, and comparative analyses,
- a statement confirming that local transfer pricing documentation has been prepared in accordance with the actual circumstances and that the applied prices are at arm’s length.
Since 2022, the statement on arm’s length pricing is no longer submitted as a separate document — it has become an integral part of the TPR form.
Who must submit the TPR-C?
The obligation applies to entities that:
- conduct transactions with related parties exceeding statutory documentation thresholds,
- engage in transactions with entities located in tax havens,
- carry out domestic transactions exempt from documentation requirements, if both parties report a profit.
Who signs the TPR-C?
According to Polish regulations, the head of the entity (as defined by the Accounting Act) is responsible for signing the TPR-C report. In the case of a multi-member management board, the report must be signed by one designated member.
It is not permitted to sign the TPR through a proxy, except for cases where the signatory is a licensed tax advisor, attorney-at-law, legal counsel, or statutory auditor.
Arm’s length statement – a significant risk for management
By signing the TPR-C, the head of the entity declares that transfer prices have been set on arm’s length terms. Providing false information may result in criminal fiscal penalties under the Fiscal Penal Code — up to 720 daily rates in fines.
Therefore, before submitting the report, it is crucial to ensure that all transactions are properly documented and that the comparative analyses confirm their compliance with the arm’s length principle.
Key deadlines for 2024 transfer pricing obligations
- By the end of the 10th month after the tax year end – preparation of local documentation (local file),
- By the end of the 11th month – submission of the TPR-C report,
- By the end of the 12th month – preparation of group documentation (master file).
For most CIT taxpayers, the deadline for submission falls on December 1, 2025.
Summary
The approaching TPR-C submission deadline is a good opportunity to verify the completeness of transfer pricing documentation and ensure that all data in the report reflect the actual circumstances.
Submitting the TPR-C should not be treated as a mere formality – it is a key element in confirming the arm’s length nature of related-party transactions and minimizing potential liability risks for company management.
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