Poland transfer pricing compliance 2026: Mandatory updates for financial transactions and the TPR form
Changes to transfer pricing regulations in Poland (see info box) also affect the preparation of the Polish transfer pricing reporting statement (TPR form). Ecovis consultants explain the details.
Scope of changes
The changes concern the method of converting the value of debt, the amount of interest accrued (on an accrual basis) and the amount of interest paid (on a cash basis) expressed in foreign currencies into PLN (Polish złoty) when reporting financial transactions on the TPR form.
For the purposes of the TPR form, the following are considered financial transactions:
- Granting or obtaining financing (credit, loan, purchase of bonds or other forms of financing)
- Liquidity management (cash pooling) – positive balances/negative balances
- Granting or obtaining a guarantee or surety
- Depositing or receiving funds
We can help you make the necessary changes to the process of completing the TPR form
Hubert Kaczyński, Tax Advisor, ECOVIS Poland, Warsaw, Poland
Practical issues
The amendment provides for the application of uniform rules for converting the value of the above-mentioned financial transactions and is intended to simplify reporting for entities submitting the TPR form.
Debts denominated in foreign currencies for the purposes of the TPR form must be converted into złoty at the average exchange rate of the National Bank of Poland (NBP) quoted on the last working day of the period for which the TPR form is being submitted. The amendment applies to the preparation of the TPR form for 2025.
Although the deadline for submitting the TPR form for 2025 is 30 November 2026 (for taxpayers whose tax year coincides with the calendar year), companies should prepare for the changes now, as they may affect the preparation of the required information.
