Transfer pricing simplifications – new deregulation bill
A draft bill amending the Polish PIT and CIT Acts has been included in the legislative agenda of the Council of Ministers. The proposed changes aim to reduce unnecessary administrative procedures, lower the cost of doing business, and enhance transparency within the tax system.
From a transfer pricing perspective, the draft introduces several important measures, including:
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liberalisation of the rules for signing the TPR information return, allowing it to be submitted by an authorised proxy,
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merger of the statement on the preparation of local transfer pricing documentation with the documentation itself,
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limitation of the scope of the TPR information return for micro and small enterprises,
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clarification of the rules governing transfer pricing adjustments between domestic entities (so-called compensating adjustments).
The draft bill should be viewed as a step towards a simpler and more taxpayer-friendly transfer pricing reporting framework. According to the legislative timetable, the adoption of the bill by the Council of Ministers is planned for Q1–Q2 2026.