Transfer pricing reporting in Poland has evolved far beyond simple documentation. The TPR-C (“Informacja o cenach transferowych”) form, introduced in 2019 under the Polish Corporate Income Tax Act and governed by Article 11t of the CIT Law, has become a cornerstone of how tax authorities assess transfer pricing risk. It is not merely a summary; it provides structured, standardized data designed for in-depth analysis.
From Documentation to Data: A Shift in Enforcement
The TPR-C form requires taxpayers to disclose comprehensive information on controlled transactions. This includes transaction types and values, the applied transfer pricing methods (such as TNMM, CUP, or Cost Plus), profitability indicators and benchmarking ranges, counterparty jurisdictions, and any adjustments or safe harbour applications. Documentation is required for controlled transactions exceeding PLN 10 million (for commodity or financial transactions) or PLN 2 million (for service or other transactions) in a year.
Crucially, all this data must align with the Local File documentation prepared under OECD and Polish transfer pricing rules.
Polish tax authorities increasingly use TPR-C data to cross-check information against Local Files and financial statements, compare profitability across taxpayers and industries, identify deviations from arm’s length ranges, and run automated risk assessment models. Even minor inconsistencies, such as differences in transaction classification or margin calculations, can raise red flags and trigger further scrutiny or audits.
The Hidden Challenge: Misalignment Between Central and Local
In many multinational groups, transfer pricing documentation is prepared centrally, while TPR-C forms are completed locally in Poland.
This creates a critical risk area:
- Different interpretations of transactions
- Inconsistent classification of costs or revenue streams
- Misalignment in financial data or segmentation
- Misalignment in functional charcaterization
- Language barriers for non-Polish speakers.
What is described one way in the Local File may be reported differently in the TPR-C form despite being based on the same underlying transaction.
This disconnect is one of the most common triggers for tax authority questions.
Manual Preparation: Time-Consuming and Risk-Prone
Preparing the TPR-C manually further compounds these risks. Data must be gathered from multiple systems and stakeholders, calculations must be replicated accurately, and both narrative and numeric consistency must be maintained, all under tight deadlines and increasing scrutiny.
TPR-C Penalties: More Than Just Administrative
The risks of getting TPR-C wrong are significant and explicitly linked to the form itself. Failure to submit, late submission, or incorrect reporting in TPR-C may result in:
- Financial penalties under the Polish Fiscal Penal Code, including:
- For lack of submission of the TPR-C form, false information in the form, or discrepancies between the TPR-C form and the Local File: a fine of up to 720 daily rates (i.e., up to approximately EUR 9.9 million) (Article 80e Section 1 Kodeks Karny Skarbowy (“KKS”- Polish Fiscal Penal Code);
- For late submission of the TPR-C form: a fine of up to 240 daily rates (i.e., up to approximately EUR 3.3 million) (Article 80e Section 2 KKS).
- Increased likelihood of a transfer pricing audit.
- Challenges to the arm’s length nature of transactions.
Additionally, the TPR-C includes a statement confirming that transfer prices are at arm’s length and that the Local File has been prepared correctly and in line with business reality. Submitting this declaration incorrectly elevates the risk exposure further.
Standardization: A Double-Edged Sword
The TPR-C is part of a broader global trend toward standardized transfer pricing reporting.
For tax authorities, this means:
- Easier data aggregation and comparison
- More effective risk profiling
- Faster identification of anomalies.
For multinational enterprises, it means:
- Less room for inconsistency
- Greater transparency across jurisdictions
- Higher stakes for accuracy.
But it also presents an opportunity: the same structured data can be used internally to monitor, align, and pre-empt risk.
TPGenie: Turning Compliance into Control
TPGenie’s TPR-C solution addresses transfer pricing risks at both local and headquarters levels while streamlining form creation and compliance.
For Headquarters it provides:
• Centralized oversight of TPR-C filings across jurisdictions.
• Ability to detect and resolve inconsistencies before submission.
• Enhanced control over global transfer pricing positions.
For Local Teams it provides:
• Guided workflows aligned with Polish TPR-C requirements.
• Automated creation of TPR-C forms in the required XML format for local submission by MNEs.
• Built-in checks comparing the TPR-C data to the Local File, flagging any inconsistencies.
• Simplified process—particularly valuable for non-native Polish speakers.
The outcome is a defensible, consistent, and audit-ready transfer pricing position.
The Bottom Line
TPR-C is no longer a checkbox exercise, it’s a window into your transfer pricing position. The question is: are you in control of the story it tells?
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