Jarosław Hein

Attorney at Law, Tax adviser (Poland)
Associate Partner
Phone: +48 32 330 12 07

Łukasz Szczygieł

Tax adviser (Poland)
Senior Associate
Phone: +48 12 378 66 32

Michał Gosek

Tax adviser (Poland)
Associate Partner
Phone: +48 61 624 49 39

Dominika Tyczka

Tax adviser (Poland)
Associate Partner
Phone: +48 71 733 97 92

The Ministry of Finance has recently published two regulations* on its website, which introduce new templates of PIT-TP and CIT-TP simplified information returns. The regulations entered into force on 6 July 2018. 

Transfer pricing – filling the information forms

Filing the PIT-TP and CIT-TP information forms is a new reporting obligation regarding the transfer pricing of transactions or other dealings which have been made between associated entities since 2017 or payments made directly or indirectly to entities from tax havens.

PIT-TP and CIT-TP forms

The forms must be filed by the end of September 2018. According to the information of the Ministry of Finance, taxpayers will be able to download the forms in electronic format from the e-Deklaracje website and file the completed forms by electronic means or in hardcopy with the tax office.

The Ministry of Finance has also published an instruction on how to fill in the PIT-TP and CIT-TP forms.  

The instruction is in the form of answers to taxpayers' most frequent questions. Below is the list of issues addressed in the instruction and referring to individual sections of the information returns: 

Section A – Taxpayer's identification details
Section B – Identification of taxpayer's relations
Section C – Information about associated entities
Section D – Taxpayer's core business and functional profile
Section E – Restructuring
Section F – Transactions with associated entities (introductory issues)
Section F.1 – Taxpayer's identification details
Section F.2 – Financial transactions
Section F.3 – Transactions and other dealings on assets
Section F.6 – Other 

The topics addressed in the instruction explain, among other things:

  • how to disclose recharging transactions;
  • how to understand the taxpayer's total revenue if the taxpayer is a member of a tax-consolidated group;
  • in which sections taxpayers should disclose revenues and costs attributable to their permanent establishment;
  • who is obliged to file a form on behalf of a partnership, or what to do if a taxpayer carries on diversified business activities. 

The publication of the Ministry of Finance is neither binding nor is to be treated as a tax ruling. It is only a general guideline that should help taxpayers to correctly fill in their information form. The instruction is available HERE 

As the completing of the PIT-TP and CIT-TP returns is a complicated task and no significant simplifications have been introduced as regards the disclosure of the required information plus there is not much time left for filing the forms, we recommend that you start working on the forms as soon as possible. 

If you are interested in more details on this topic, members od our transfer pricing team will be happy to help you in branches in Gdańsk, Gliwice, Cracow, Poznań, Warsaw and Wrocław.