Simplifications in transfer pricing await President’s signature

This article is an update to the post “Amendments of regulations on TPR information and transfer pricing, and new sanctions under the Fiscal Penal Code” from April 2026.

Good news! On 18 September 2026, the Sejm passed the law which simplifies transfer pricing repoting rules, and several days later – on 24 September – the Senate approved it without any modifications. The law is currently awaiting President's signature. 

What major simplifications to transfer pricing reporting obligations will be made soon? To explain this, we have compiled a summary of the most important changes for taxpayers.

Changes to the TPR-C form

Under the proposed amendments, the obligation for the TPR-C form to be signed and submitted by a board member or a professional representative who is an advocate, an attorney-at-law, a tax adviser, or a statutory auditor will be abolished.

Once the new regulations take effect, the TPR-C form may be signed by a representative holding a power of attorney to sign tax returns filed electronically. Therefore, the rules for signing the TPR-C form will be aligned with the general rules for submitting tax returns. 

Repealing certain obligations for micro- and small enterprises

Simplification of the procedure for submitting transfer pricing information is not the only good news for taxpayers. The amendment also repeals the obligation for micro- and small entreprises who submit TPR-C forms to provide general financial indicators.

Standalone statement on the preparation of transfer pricing documentation

Another change involves the statement on the preparation of transfer pricing documentation, which confirms that local file is consistent with the actual state of affairs, and that the prices used in transactions between related entities or in transactions with an entity from a country classified as a tax haven comply with the arm's length principle. 

To date, the statement on the preparation of transfer pricing documentation has been incorporated into the TPR-C form. However, under the proposed changes, the statement will no longer be an element of the TPR-C form or be included in the transfer pricing documentation, as originally proposed.

It is currently known that the statement is to be signed with a qualified electronic signature, a trusted signature, or a personal signature. At this stage, however, there is still no information on the technical details of the process for submitting this document.

Transfer pricing adjustments also in domestic transactions

The Act amending the Corporate Income Tax Act and the Personal Income Tax Act also clarifies the provisions concerning transfer pricing adjustments set out in Article 11e of the Corporate Income Tax Act. Thus, any doubts taxpayers’ doubts regarding transfer pricing adjustments being made only in transactions with international entities have been dispelled.

A welcome development for taxpayers obliged to prepare transfer pricing documentation

The changes to transfer pricing proposed by the amendment will apply to transactions documented for the tax year beginning after 31 December 2025. 

It means that, for entities whose tax year coincides with the calendar year, the first year to which the changes will apply will be 2026.

These changes should be viewed positively, as it appears that the intended purpose – which is to simplify the reporting obligations associated with submitting the TPR-C form – will be achieved. Furthermore, the confirmation of the possibility of making transfer pricing adjustments in transactions between domestic taxpayers is clearly a positive development, rendering the interpretation unambiguous. However, there is no doubt that the procedure for submitting the statement on the preparation of transfer pricing documentation, which will no longer be an element of the TPR-C form, requires further clarification.