Extension of deadlines to perform transfer pricing obligations


“Shield 4.0” extends the deadlines for all obligated entities to file transfer pricing information (TPR), declarations on preparation of local transfer pricing documentation, and enclosures of group transfer pricing documentation. The earlier regulations extended the deadlines only for selected taxpayers.

The change in deadlines is intended to facilitate performance of transfer pricing obligations, and is connected with the extension of deadlines for preparation and approval of financial reports for 2019 due to COVID-19.

The COVID-19 legislative relief package in Poland referred to as “Shield 4.0” provides for extension of deadlines for:

  • Filing information on transfer pricing for legal persons (TPR-C) and natural persons (TPR-P)
    • Until 31 December 2020, if the deadline determined under the Corporate Income Tax Act or Personal Income Tax Act falls between 31 March and 30 September 2020
    • By three months, if the deadline determined under the CIT Act or PIT Act falls between 1 October 2020 and 31 January 2021
  • Filing a declaration on preparation of local transfer pricing documentation
    • Until 31 December 2020, if the deadline determined under the CIT Act or PIT Act falls between 31 March and 30 September 2020
    • By three months, if the deadline determined under the CIT Act or PIT Act falls between 1 October 2020 and 31 January 2021
  • Supplementing local transfer pricing documentation with group transfer pricing documentation
    • Through the end of the third month following the extended deadline for filing the declaration on preparation of local transfer pricing documentation.

Shield 4.0 also excludes application of transfer pricing regulations with respect to transactions between medical schools and healthcare facilities established and operated by medical schools within the meaning of the Healthcare Act.

Shield 4.0 entered into force on 24 June 2020.

Wojciech Marszałkowski, adwokat, Mateusz Rowiński, Tax practice, Wardyński & Partners