Poland: Update on transfer pricing legislation

Poland: Update on transfer pricing legislation

Poland’s lower house (Sejm) on 11 September 2015 passed a bill containing amendments to the tax laws, including changes to the rules governing transactions between related parties—the transfer pricing rules. If enacted, the transfer pricing rules would be effective 1 January 2017.


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Among the legislative changes, new rules would:

  • Increase the threshold for determining a “capital relationship” between two entities from 5% to 25%
  • Revise the requirements for when transfer pricing documentation must be prepared
  • Specifies information to be provided in the transfer pricing documentation

The bill now is subject to consideration by the Polish Senate, and the earliest session will be 30 September and 1 October 2015.


Read a September 2015 report [PDF 314 KB] prepared by the KPMG member firm in Poland: Amendments to the transfer pricing regulations passed by the Sejm

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