Poland: Expanded transfer pricing, country-by-country reporting enacted

Country-by-Country reporting in Poland

New law in Poland expands the requirements for transfer pricing documentation, and includes country-by-country (CbC) reporting. The new provisions essentially reflect the recommendations made in Action 13 the OECD’s base erosion and profit shifting (BEPS) project, and provide for CbC, master file and local file reporting.


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The legislation was passed by the lower house (Sejm) in September 2015, and sent to the upper house for consideration.  Following this, the president signed the bill into law.  Read more on the then-pending amendments to the transfer pricing reporting rules: TaxNewsFlash-Transfer Pricing 


Read a 2015 report [PDF 299 KB] (English) or a 2015 report [PDF 293 KB] (Polish): Transfer Pricing Alert

  • Master file: The threshold is €20 million and it is binding from 2017.
  • Local file including local benchmarking (comparables) is binding from 2017.
  • CbC is binding from 2016.


For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services group in Poland:

Jacek Bajger | +48 225 281 173 | Jbajger@kpmg.pl

Monika Palmowska | +48 225 281 193 | mpalmowska@kpmg.pl

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