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Transfer pricing reports present detailed and easily processed data on related party settlements. In the current era, it is important to have a transfer pricing risk management strategy, in which it becomes important to correctly present the facts and key assumptions for the settlements adopted in the documentation, and to send the management statement and the TPR-C form on time.
In 2024, taxpayers will file this form for the second time according to the revised 2023 model and delivery method. The main difference from the previous TPR-C regulations is the possibility of filing the form through an attorney who is an attorney, legal counsel, tax advisor or auditor. Previously, it was not possible to transfer this obligation to an attorney.
Another important change is that there is no need to submit a separate statement on the preparation of local transfer pricing documentation and the market prices used. The statement according to the new regulation is an integral part of the TPR-C, the submission of which to the authority is the same as the submission of the aforementioned statement.
Important changes also included the reporting of the restructuring process. Previously, the value of remuneration in connection with restructuring had to be reported; currently, taxpayers are required to disclose whether this remuneration was actually paid or received and in what form (cash or otherwise).
Taxpayers fulfilling 2024 reporting obligations for 2023 will be required to prepare local transfer pricing documentation by the end of the 10th month after the end of the tax year and send the TPR-C along with a statement from the entity that the local transfer pricing documentation was prepared in accordance with the actual state of affairs.
Transfer pricing is constantly attracting the interest of tax authorities. Particularly closely scrutinized are transactions conducted with entities based in so-called tax havens. In this case, the limits on the value of transactions above which TP must be applied are much lower.
During an audit or as part of verification activities, the auditors have the right to call on the taxpayer to submit transfer pricing documentation. The regulations require the taxpayer to submit the documentation within 14 days.
It should be remembered that taxpayers are not obliged to prepare transfer pricing documentation in every situation. However, the absence of this obligation does not relieve the taxpayer from determining them in accordance with the arm's length principle.
Penalties under the CCC for failure to comply with documentation obligations are set in daily rates. Their amount cannot be less than 1/30 of the minimum wage or exceed its four hundred times. As of January 1, 2024, the minimum wage is PLN 4,242, and as of July 1, 2024, it is PLN 4,300. Compared to the amount of July 1, 2023 - PLN 3,600, this is an increase of 19.4%. Failure to prepare the transfer pricing form on time carries a maximum penalty of a fine of 240 daily rates.