At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-26. Tax authority: Ministerstwo Finansów / Krajowa Administracja Skarbowa (Ministry of Finance and National Revenue Administration). Summaries are simplified; check the linked official source before relying on them.
The law
#Transfer pricing rules are in Chapter 1a of the Corporate Income Tax Act (CIT Act, art. 11a to 11t). Related parties must set prices on the terms unrelated parties would agree, and the tax authority can reset income that is too low because of the relationship (art. 11c). The authority can also ignore a transaction, or replace it with a different one, if rational unrelated parties would not have entered into it (art. 11c(4)). Parties are related at 25% of shares, votes or profit rights, or through real influence over key decisions (art. 11a(2)). A Ministry of Finance regulation (Dz.U. 2023 poz. 1129) covers comparability.
Documentation
#A local file must be ready in electronic form by the end of the 10th month after the tax year for each type of controlled transaction above PLN 10m (goods and financial) or PLN 2m (services and other), counted separately for costs and revenue (art. 11k). Dealings with tax havens have lower thresholds of PLN 2.5m (financial) and PLN 0.5m (other), even with unrelated parties (art. 11k(2a) and 11o). A master file is due by the end of the 12th month if the group has consolidated revenue above PLN 200m, and it may be in English (art. 11p). The TPR-C return is due by the end of the 11th month and includes the statement that the local file is correct (art. 11t). Files must be handed over within 14 days of a request (art. 11s).
Methods
#Art. 11d lists five methods: comparable uncontrolled price, resale price, cost plus, transactional net margin and profit split. The taxpayer must use the most appropriate method in the circumstances. If none of them can be applied, another method or a valuation technique may be used. Safe harbours exist for low value-adding services (5% markup, art. 11f) and for loans up to PLN 20m using a published base rate and margin (art. 11g).
Penalties
#If the authority adjusts transfer prices, it adds an extra tax of 10% of the understated income (Tax Ordinance art. 58a and 58b). The rate doubles on the part above PLN 15m or if documentation is not handed over, and triples if both apply (art. 58c). Managers can also face fines under the Fiscal Penal Code: up to 720 daily rates for no local file, no master file or no TPR, and up to 240 daily rates for a late one (art. 56c and 80e). Missing or wrong CbC filings can bring a fine of up to PLN 1m (exchange act art. 90 and 91).
Pillar Two
#The Global Minimum Tax Act (Dz.U. 2024 poz. 1685) applies the IIR, the QDMTT and the UTPR to tax years starting from 1 January 2025, for groups with revenue of at least EUR 750m in 2 of the 4 prior years. Each Polish entity files a GloBE information return (GIR) by the end of the 15th month after year end, unless it is filed in an EU country on Poland's exchange list. Top-up tax returns (GLB-I1, GLB-D1, GLB-U1) and payment are due by the end of the 18th month. Longer first-year periods (18 months for the GIR, 21 for returns) do not apply to groups that were already under Pillar Two rules elsewhere in 2024 (art. 156(3)), so most large groups use 15 and 18 months for 2025.
Other rules
#The CIT return (CIT-8) is due by the end of the third month after the tax year. Under Tax Ordinance art. 12 par. 5, a deadline on a Saturday, Sunday or public holiday moves to the next working day. Poland offers unilateral, bilateral and multilateral APAs and mutual agreement procedures under tax treaties and the EU Arbitration Convention. A draft law published in March 2026 would change the local file and TPR rules from 2026 tax years, but it was not enacted when this was checked.
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | Corporate income tax return (CIT-8) Filed electronically, and the tax paid, by the end of the third month after the tax year (31 March for a calendar year; art. 27(1) CIT Act). For a non-calendar year the statute says 'third month of the following year', which the tax service reads as three months after year end. There is no standing extension; past extensions came only from one-off Ministry of Finance regulations. | 3 months after year end (e.g. Mar 31, 2026) | All Polish corporate income tax payers, except those fully exempt. | CIT Act art. 27 (Dz.U. 2026 poz. 554) |
| 2 | CbC notification (CBC-P) Each Polish group entity tells the Head of the National Revenue Administration whether it is the parent, the designated filer or neither, and if neither names the reporting entity and country, within 3 months after the end of the group's reporting year (art. 86(1)). The exchange act has no rule moving weekend deadlines, so the calendar date is shown. Penalty: up to PLN 1m (art. 90 and 91). | 3 months after year end (e.g. Mar 31, 2026) | Polish entities in a group whose consolidated revenue in the prior year exceeded PLN 3.25bn (or EUR 750m for groups reporting in another currency). | Tax Information Exchange Act art. 86 (consolidated text) |
| 3 | Local file (lokalna dokumentacja cen transferowych) Must be ready, in electronic form, by the end of the 10th month after the tax year (art. 11k(1)), so 31 October for a calendar year. Tax Ordinance art. 12 par. 5 may move a weekend date (31 October 2026 is a Saturday) to the next working day, but the file is only prepared, not filed, and no official source confirms the move, so plan for the calendar date. Penalties: Fiscal Penal Code art. 56c. | 10 months after year end (e.g. Oct 31, 2026) (a Saturday: may move to the next working day) | Related parties with a homogeneous controlled transaction above PLN 10m (goods or financial) or PLN 2m (services or other) in the tax year, counted separately for costs and revenue. Tax haven counterparties: PLN 2.5m (financial) and PLN 0.5m (other), also for transactions that are not controlled. Domestic-only transactions are exempt if no party has a tax exemption or loss. Transactions covered by an APA, intragroup tax group transactions, safe harbour low value-adding services and loans, and pure cost pass-through are also exempt. | CIT Act art. 11k (Dz.U. 2026 poz. 554) |
| 4 | Transfer pricing information return (TPR-C) Filed electronically with the head of the tax office by the end of the 11th month after the tax year (30 November for a calendar year; art. 11t(1)). It includes the statement that the local file is accurate and prices are at arm's length. A proxy may sign only if an advocate, legal adviser, tax adviser or statutory auditor (art. 11t(5)). Penalty: Fiscal Penal Code art. 80e. | 11 months after year end (e.g. Nov 30, 2026) | Related parties that must prepare a local file, and related parties whose controlled transactions are only exempt ones (domestic-only, APA, cost pass-through, low value-adding services, safe harbour loans). Exempt-only entities file a short version without financial ratios. | CIT Act art. 11t (Dz.U. 2026 poz. 554) |
| 5 | Group (master) file (grupowa dokumentacja cen transferowych) Prepared by the end of the 12th month after the tax year (art. 11p(1)), by the entity or another group member, and attached to the local file. It can be in English, and the authority may ask for a Polish version within 30 days (art. 11p(4)). Failing to prepare or attach it is a fiscal offence (art. 56c). | 12 months after year end (e.g. Dec 31, 2026) | Related parties that must prepare a local file, whose financial statements are fully or proportionally consolidated, and that belong to a group preparing consolidated statements with consolidated revenue above PLN 200m in the previous financial year. | CIT Act art. 11p (Dz.U. 2026 poz. 554) |
| 6 | Country-by-country report (CBC-R) Filed within 12 months after the end of the reporting financial year (art. 83(1)). Late, missing or incomplete filing can bring a fine of up to PLN 1m (art. 90 and 91), and a false return is a fiscal offence (Fiscal Penal Code art. 80d). | 12 months after year end (e.g. Dec 31, 2026) | Polish parent entity of a group with consolidated revenue above PLN 3.25bn (or EUR 750m if the group reports in another currency), or a Polish entity that must file locally under art. 84. | Tax Information Exchange Act art. 83 (consolidated text) |
| 7 | GloBE information return (GIR-1) Due by the end of the 15th month after the tax year (art. 133(1)), so 31 March 2027 for calendar 2025. The 18-month first-year period (art. 133(10)) applies only if 2025 is the first year any Pillar Two rule covered the Polish entities; it does not apply to groups already under such rules elsewhere in 2024 (art. 156(3)), so check before relying on 30 June 2027. Not needed if the GIR is filed in a country on Poland's exchange list (art. 133(4)), which in practice means EU states. Penalties: Fiscal Penal Code art. 56f. | 15 months after year end (e.g. Mar 31, 2027) | Constituent entities in Poland of groups with revenue of at least EUR 750m in 2 of the 4 prior years. | Global Minimum Tax Act art. 133 (Dz.U. 2024 poz. 1685) |
| 8 | Pillar Two notices (GLB-Z1 initial phase, GLB-Z2 filing entity abroad) GLB-Z1 reports the start of the group's initial phase of international activity (art. 129(4)) and GLB-Z2 names the entity that filed the GIR abroad and its country (art. 133(7)). Both are due by the end of the 15th month; the 18-month first-year period (art. 129(5), 133(10)) does not apply to groups already under Pillar Two rules elsewhere in 2024 (art. 156(3)). A late GLB-Z2 is a fiscal offence (Fiscal Penal Code art. 80h). | 15 months after year end (e.g. Mar 31, 2027) | Polish entities of in-scope groups that are in the initial phase of international activity (art. 128), or whose GIR is filed abroad. | Global Minimum Tax Act art. 129 and 133 (Dz.U. 2024 poz. 1685) |
| 9 | Top-up tax returns and payment (GLB-I1, GLB-D1, GLB-U1) Returns and payment are due by the end of the 18th month after the tax year (art. 134(1)), so 30 June 2027 for calendar 2025. The 21-month first-year period (art. 134(2)) applies only if 2025 is the first year any Pillar Two rule covered the Polish entities, and not to groups already under such rules elsewhere in 2024 (art. 156(3)). Several Polish taxpayers of one group can choose one entity to file for all (art. 135). | 18 months after year end (e.g. Jun 30, 2027) | Taxpayers of the global top-up tax (IIR), domestic top-up tax (QDMTT) or undertaxed profits tax (UTPR) in Poland. | Global Minimum Tax Act art. 134 (Dz.U. 2024 poz. 1685) |
| 10 | Choice of one Polish entity to file returns (GLB-Z3) The notice must be sent no later than the due date of the return for the first tax year covered by the choice. The choice lasts up to 5 years and is ineffective if the notice is late (art. 135(2) and (3)). | With Top-up tax returns and payment (GLB-I1, GLB-D1, GLB-U1) (e.g. Jun 30, 2027) | Two or more Polish taxpayers of the same top-up tax in one group that want one of them to file for all. | Global Minimum Tax Act art. 135 (Dz.U. 2024 poz. 1685) |
| 11 | Hand over local file or master file on request The tax authority may ask for the file once the preparation deadline has passed. The entity must hand it over within 14 days of the request being delivered (art. 11s(1)). A request for a short-form file without benchmarking (low-value services or loan safe harbour checks) gives 30 days (art. 11s(2)). If the master file is in English, the authority can ask for a Polish version within 30 days (art. 11p(4)). | Within 14 days of a tax authority request | Any related party that must prepare a local or group file. | CIT Act art. 11s (Dz.U. 2026 poz. 554) |
Official texts
#- CIT Act of 15 February 1992 (consolidated text, Dz.U. 2026 poz. 554) (Not protected by copyright: normative acts and official documents are excluded from copyright (art. 4 points 1 and 2 of the Act on Copyright and Related Rights))
- Tax Ordinance (Ordynacja podatkowa), consolidated text Dz.U. 2026 poz. 622 (Not protected by copyright: normative acts and official documents are excluded from copyright (art. 4 points 1 and 2 of the Act on Copyright and Related Rights))
- Fiscal Penal Code (Kodeks karny skarbowy), consolidated text Dz.U. 2025 poz. 633 (Not protected by copyright: normative acts and official documents are excluded from copyright (art. 4 points 1 and 2 of the Act on Copyright and Related Rights))
- Act of 9 March 2017 on the exchange of tax information with other countries (CbC), consolidated text Dz.U. 2025 poz. 1379 as amended (Not protected by copyright: normative acts and official documents are excluded from copyright (art. 4 points 1 and 2 of the Act on Copyright and Related Rights))
- Global Minimum Tax Act of 6 November 2024 (Dz.U. 2024 poz. 1685) (Not protected by copyright: normative acts and official documents are excluded from copyright (art. 4 points 1 and 2 of the Act on Copyright and Related Rights))
- Regulation on transfer pricing for CIT (Dz.U. 2023 poz. 1129) and regulation on the TPR information return (Dz.U. 2025 poz. 1744) (Not protected by copyright: regulations are normative acts (art. 4 point 1 of the Act on Copyright and Related Rights))