Dear Sirs,

We would like to inform you that as of 1 January 2022, changes to the transfer pricing provisions of the tax law came into force. In fact, most of these changes will be relevant only at the moment of verification of the obligation to prepare transfer pricing documentation for the year 2022. Nevertheless, some of the changes introduced are worth getting acquainted with already now.

We hereby present to you a summary of the changes introduced:

  1. Changes in formal requirements for preparing transfer pricing documentation and deadlines related to transfer pricing
  2. Changes in the TP-R
  3. Changes in the definition of transaction value
  4. Changes in the conditions for transfer pricing adjustments (Article 11e of the CIT Act)
  5. Extension of the catalogue of exclusions from the obligation to prepare local documentation
  6. Extension of the catalogue of exemptions from the obligation to prepare local documentation
  7. Waiving the preparation of comparative analysis/compliance analysis for selected entities
  8. Exemption from filling in information on contracts concluded with non-residents (ORD-U) for selected entities
  9. Extension of the scope of activities subject to penal-fiscal liability
  10. Other changes

1. Changes in formal requirements

2. Changes in TP-R

3. Changes in the definition of the value of transactions

4. Changes in the conditions for transfer pricing adjustments (Article 11e of the CIT Act)

5. Extension of the catalogue of exclusions from the obligation to prepare local documentation

6. Extension of the catalogue of exemptions from the obligation to prepare local documentation

7. Waiving the obligation to prepare a comparative analysis/compliance analysis for selected entities

8. Exemption from the preparation of the ORD-U information

9. Extension of the scope of activities subject to penal-fiscal liability

10. Other changes

Should you have any questions, we are at your disposal.

Best regards,