Poland: transfer pricing (2026)

General reference only. This skill is general tax reference material for AI-assisted work. It has not been reviewed for any specific company's facts. Do not rely on it to file, pay or take a position without review by a qualified professional in Poland.

Which text of the law. Article numbers are those of the CIT Act (ustawa z dnia 15 lutego 1992 r. o podatku dochodowym od osób prawnych), consolidated text Dz.U. 2026 poz. 554. Of the later amendments, only Dz.U. 2026 poz. 1371 (published 21 October 2026, in force from 5 November 2026, 14 days after publication) touches the transfer pricing chapter: it changes the TPR return for tax years that start after 31 December 2025, and rewrites the art. 11e condition on foreign counterparties. The PIT Act (Dz.U. 2026 poz. 592) has the same rules for individuals and partnerships in art. 23m to 23zf; the article map is in "Who this applies to".

Sibling skills. CIT rates, base, the interest cap, minimum tax, shifted-income tax, CFC and withholding: pl-cit-corporate-tax. Individuals and sole traders: pl-income-tax. This skill does not repeat them.

Who this applies to

Related parties (art. 11a(1)(4) and (2)). Two parties are related where:

• one exerts significant influence over the other; or
• the same party, or a spouse or relative up to the second degree of an individual with significant influence, exerts significant influence over both; or
• they are a tax-transparent partnership and its partner, a limited or limited joint-stock partnership taxed as a company and its general partner, a general partnership taxed as a company and its partner, or a taxpayer and its foreign permanent establishment (art. 11a(1)(4)(c)-(d)).

Significant influence (art. 11a(2)-(3)). Holding, directly or indirectly, at least 25% of the capital, of the votes in the supervisory, decision-making or managing bodies, or of the rights to profits, losses or assets (including fund units); or an individual's actual ability to steer key business decisions; or marriage, kinship or affinity to the second degree. Indirect holdings use the lowest percentage along a chain, and the sum where there are several chains (art. 11a(3)). Relations set up without good economic reasons, such as circular structures, also count as related (art. 11a(4)).

Controlled transaction (art. 11a(1)(6)). Any economic activity between related parties whose terms were set or imposed by the relationship, identified from how the parties actually behave. It includes attributing income to a permanent establishment.

Tax havens (art. 11i, 11o). Transfer pricing rules also apply to a transaction with an unrelated party resident in a country on the harmful tax competition list (Dz.U. 2024 poz. 1928), with lower documentation thresholds.

Out of the chapter altogether (art. 11b). Prices set by statute or regulation, some Bank Guarantee Fund and medical university transactions, and the special-purpose defence investment company.

PIT Act article map. For individuals and PIT-taxed partnerships, read: 23m (definitions), 23n (exclusions), 23o (arm's length), 23p (methods), 23q (adjustments), 23r (low-value services), 23s (loans), 23u (tax havens), 23w (local file and thresholds), 23x (transaction value), 23z (exemptions), 23za (unrelated tax-haven deals), 23zb (master file), 23zc (contents), 23zd (three-year update), 23ze (request), 23zf (TPR). The CIT rules below apply in the same way.

Rates, bands and thresholds

Item	Rate or amount	Year	Source
Significant influence	25% of capital, votes or profit rights, direct or indirect	2026	CIT Act art. 11a(2)
Local file threshold, goods	above PLN 10,000,000 per homogeneous transaction, per side	2026	art. 11k(2)(1), (3)
Local file threshold, financial	above PLN 10,000,000 (loan capital, bond face value, guarantee amount)	2026	art. 11k(2)(2), art. 11l(1)
Local file threshold, services	above PLN 2,000,000	2026	art. 11k(2)(3)
Local file threshold, other transactions	above PLN 2,000,000	2026	art. 11k(2)(4)
Thresholds with a tax-haven party, related or not	above PLN 2,500,000 financial; above PLN 500,000 other	2026	art. 11k(2a), art. 11o(1)
Master file	attach where the group has consolidated accounts and consolidated revenue above PLN 200,000,000 in the prior financial year	2026	art. 11p(1)
Loan safe harbour, base rate	PLN: WIBOR 3M, WIRON 3M compounded or POLSTR 3M compounded; USD: 90-day Average SOFR; EUR: EURIBOR 3M; CHF: SARON 3M compound; GBP: SONIA 3M compound	from 1 January 2026	MF notice, M.P. 2025 poz. 1249; art. 11g(1)(1)
Loan safe harbour, margin	borrower: at most 2.6 points; lender: at least 2.0 points (if the base rate is below zero, add its absolute value)	from 1 January 2026	M.P. 2025 poz. 1249
Loan safe harbour, size and term	total related-party loan capital up to PLN 20,000,000, counted separately for loans given and taken; term up to 5 years	2026	art. 11g(1)(3)-(4)
Low-value services safe harbour	mark-up at most 5% of costs when buying; at least 5% when providing	2026	art. 11f(1)(1)
Additional tax liability (dodatkowe zobowiązanie podatkowe)	10% of the understated income or overstated loss	2026	Tax Ordinance art. 58b § 1
Doubled rate	20% on the part of the base above PLN 15,000,000, or on the part linked to a transaction whose documentation was not submitted	2026	Tax Ordinance art. 58c § 1(1), (3)
Tripled rate	30% where both doubling grounds apply	2026	Tax Ordinance art. 58c § 2
Fiscal penal fine, no local file, no master file attached, or untrue file	up to 720 daily rates	2026	Kodeks karny skarbowy art. 56c § 1-2
Fiscal penal fine, local file late	up to 240 daily rates	2026	KKS art. 56c § 3
Fiscal penal fine, no TPR or untrue TPR / late TPR	up to 720 / up to 240 daily rates	2026	KKS art. 80e § 1-2
Fine for a minor case (fiscal petty offence)	1/10 to 20 times the minimum wage: PLN 480.60 to PLN 96,120 with the 2026 minimum wage	2026	KKS art. 48 § 1, art. 56c § 4, art. 80e § 3
One daily rate	from 1/30 of the minimum wage to 400 times that: PLN 160.20 to PLN 64,080 with the 2026 minimum wage of PLN 4,806	2026	KKS art. 23 § 3; minimum wage 2026, Dz.U. 2025 poz. 1242
APA application fee	1% of the transaction value; unilateral, domestic parties only: PLN 5,000 to PLN 50,000; unilateral with a foreign party: PLN 20,000 to PLN 100,000; bilateral or multilateral: PLN 50,000 to PLN 200,000; renewal: half	2026	APA and dispute act, Dz.U. 2023 poz. 948, art. 98
APA term	at most 5 tax years; renewable for further periods of up to 5 years	2026	Dz.U. 2023 poz. 948, art. 95(2), (4)
Country-by-country report threshold	consolidated revenue of PLN 3,250,000,000 (groups reporting in PLN) or EUR 750,000,000	2026	Exchange of tax information act, Dz.U. 2025 poz. 1379, art. 82(2)
CbC penalty	up to PLN 1,000,000	2026	Dz.U. 2025 poz. 1379, art. 90-91

The taxable base

The arm's length rule (art. 11c). Related parties must set transfer prices on the terms unrelated parties would agree. Where the relationship leads to lower income (or a higher loss) than unrelated parties would show, the tax authority sets the income without those terms (art. 11c(2)). It looks at what the parties actually did, not only the contract (art. 11c(3)).

Recharacterisation (art. 11c(4)-(5)). If rational unrelated parties would not have done the deal at all, or would have done a different one, the authority can disregard it, or replace it with the "proper transaction" (transakcja właściwa). It cannot do this only because the price is hard to verify or because no comparables exist.

Methods (art. 11d). Comparable uncontrolled price, resale price, cost plus, transactional net margin, profit split; another method or valuation technique where none of these works. The authority uses the taxpayer's method unless another one is more appropriate (art. 11d(4)). The detailed comparability rules are in the MF documentation regulation (CIT, consolidated Dz.U. 2023 poz. 1783), issued under art. 11j(1).

The taxpayer's own adjustment (art. 11e). The taxpayer can adjust revenue or costs after year end if all of these hold:

1. the terms set during the year were arm's length;
2. circumstances changed, or actual costs or revenues became known, so an adjustment is needed to stay at arm's length;
3. when adjusting, the taxpayer holds a statement or accounting document from the related party confirming the same adjustment;
4. where the related party has no residence, seat or management in Poland, there is a legal basis for exchanging tax information with its state. (This "foreign party only" wording comes from Dz.U. 2026 poz. 1371; before it, the information-exchange condition read as applying to every related party.)

Low-value services safe harbour (art. 11f). The authority will not adjust the mark-up on low-value-adding services if: the mark-up was set by cost plus or TNMM and is at most 5% (buyer) or at least 5% (provider); the provider is not in a tax haven; and the buyer holds a calculation showing the costs, the allocation keys and a functional analysis. The services must be listed in annex 6 to the CIT Act, be supporting services, not be the group's main business, be sold to unrelated parties for no more than 2% of their total value, and not be resold.

Loan safe harbour (art. 11g). The authority will not adjust the interest on a related-party loan, credit or bond issue (art. 11g(3)) if all of these hold:

1. the annual rate on the contract date is set from the base rate type and the margin in the MF notice current on that date (for 2026: table above); a change to the rate counts as a new contract date (art. 11g(1a));
2. no fees other than interest (no commission or bonus);
3. term up to 5 years;
4. during the tax year, total loan capital with related parties is at most PLN 20,000,000, counted separately for loans given and loans taken (foreign currency converted at the NBP rate on the last working day before payout, art. 11g(2));
5. the lender is not in a tax haven.

Losing a safe harbour is not an automatic adjustment to the safe-harbour rate. It only removes the protection. The authority then tests the price by the art. 11d methods.

Additional tax liability. When the authority adjusts income under art. 11c, it also sets an additional tax liability under the Tax Ordinance (see "Penalties and interest"). It is a separate charge on top of the 19% (or 9%) CIT on the adjustment computed under pl-cit-corporate-tax.

Deadlines and filing

Who must prepare a local file (art. 11k). Every related party, for each homogeneous controlled transaction whose value in the tax year exceeds the threshold for its type. Thresholds apply separately to each homogeneous transaction and separately to the cost side and the revenue side (art. 11k(3)). The value is net of recoverable VAT (art. 11l(2a)), counted from invoices, then contracts, then payments (art. 11l(2)), regardless of how many invoices, payments or related counterparties there are (art. 11k(4)). Whether transactions are homogeneous depends on their economic substance, the comparability criteria and the method (art. 11k(5)).

Exemptions from the local file (art. 11n). The main ones:

• Domestic transactions: between Polish-resident related parties only, where, in that tax year, none of them uses the art. 6 subjective exemption or the special-zone and investment-decision exemptions (art. 17(1)(34) and (34a)), and none had a tax loss (art. 11n(1)). A Polish permanent establishment of an EU/EEA company is treated the same way on the same conditions (art. 11n(1a));
• transactions covered by an APA, investment agreement or tax agreement (art. 11n(2));
• transactions within a tax capital group, PGK (art. 11n(4));
• relations only through the State Treasury or local government (art. 11n(5));
• pure on-charges of third-party costs with no mark-up, made promptly and not linked to another controlled transaction (art. 11n(10));
• low-value services that meet art. 11f (art. 11n(11)), and loans that meet art. 11g (art. 11n(12)).

Content (art. 11q). Description of the entity, description of the transaction with a functional analysis, a transfer pricing analysis (a benchmarking study, or a compliance analysis where benchmarking is not suitable), and financial information. A micro or small entrepreneur under art. 7(1)(1)-(2) of the Entrepreneurs' Law (judged on the last tax year) may leave out the benchmarking or compliance analysis (art. 11q(3a)-(3b)). The benchmark must be updated at least every 3 years, or sooner if the economic environment changes significantly (art. 11r). The file is kept in electronic form.

On request (art. 11s). The file must be handed over within 14 days of a request, which the authority can make only after the preparation deadline. Where there are signs that a controlled transaction is undervalued or that the art. 11f or 11g conditions are not met, the authority can ask a taxpayer that is not a micro-entrepreneur to prepare and hand over, within 30 days, a local file without benchmarking for the transactions it names, stating its grounds (art. 11s(2)).

Calendar for tax year 2026 (calendar-year company).

Step	Deadline	Rule
Local file	end of the 10th month after year end: 31 October 2027. That day is a Sunday and 1 November is a public holiday, so the Tax Ordinance art. 12 § 5 moves it to Tuesday 2 November 2027	art. 11k(1); Tax Ordinance art. 12 § 5; public holidays act art. 1
TPR-C return (informacja o cenach transferowych), filed electronically with the tax office	end of the 11th month: 30 November 2027	art. 11t(1), (1b)
Master file attached to the local file	end of the 12th month: 31 December 2027	art. 11p(1)
CbC notification (CbC-P), each group member in Poland	3 months after the end of the group's reporting year	Dz.U. 2025 poz. 1379, art. 86(1)
CbC report (CbC-R) by a Polish parent	12 months after the end of the reporting year	Dz.U. 2025 poz. 1379, art. 83(1)

Who files a TPR (art. 11t(1)). Every related party that must prepare a local file (for those transactions), and every related party with controlled transactions exempt under art. 11n points 1 to 2 or 10 to 12 (domestic, PE, APA, on-charges, low-value services, safe-harbour loans), even though no local file is needed. Tax-haven transactions under art. 11o are reported too (art. 11t(3)). Form: TPR-C for CIT, TPR-P for PIT. The current published version is TPR-C(6), used for tax years beginning after 31 December 2024 (podatki.gov.pl, Ceny transferowe).

TPR changes for tax years starting after 31 December 2025 (Dz.U. 2026 poz. 1371, art. 2 and art. 4).

• The statement that the local file is true and the prices are arm's length (art. 11t(2)(7) and (2b)) is repealed.
• Micro and small entrepreneurs (judged on the last tax year) leave out the general financial information (new art. 11t(2c)-(2d)).
• For exempt transactions under art. 11n points 1 to 2 and 10 to 12, the TPR leaves out the financial data, the pricing and method data, and the additional explanations (art. 11t(4) as amended).
• The rules on who signs (art. 11t(5) and (5a)) are repealed. An e-filing power of attorney under the Tax Ordinance now also covers signing the TPR (art. 11t(5b)), and the Tax Ordinance rules on correcting returns apply to the TPR (art. 11t(5c)).
• The MF must issue a new TPR regulation; the old one lapses when the new one takes effect, and no later than 30 June 2027 (art. 5 of the amending act). A new TPR-C form version for 2026 had not been published when this skill was written.

Penalties and interest

Additional tax liability (Tax Ordinance art. 58a to 58e). When the authority issues a decision under the arm's length rules (CIT Act chapter 1a, division 2), it also sets an additional tax liability (art. 58a § 1(4)):

• 10% of the understated income or overstated loss arising from the decision (art. 58b § 1);
• 20% on the part of that base above PLN 15,000,000 (art. 58c § 1(1));
• 20% on the part linked to a transaction for which the taxpayer did not submit its local file or master file (art. 58c § 1(3));
• 30% where both of the last two apply (art. 58c § 2).

The 14-day cure: if the documentation was submitted but incomplete, and the taxpayer completes it in full within the period the authority sets (at most 14 days), the documentation doubling does not apply (art. 58c § 3). The good-faith waiver in art. 58a § 3 covers only the GAAR, treaty and hybrid cases in § 1 points 1 to 3, not transfer pricing adjustments. An individual punished under the Fiscal Penal Code for the same act is not charged the additional liability (art. 58e).

Late payment interest. The CIT on the adjustment carries late payment interest from the original due date; the rate (10.50% a year from 5 March 2026) is in pl-cit-corporate-tax.

Fiscal penal fines (Kodeks karny skarbowy). These hit the individuals responsible (usually board members), with the company liable in the alternative under art. 24:

• no local file, or no master file attached, or a file that does not reflect reality: up to 720 daily rates (art. 56c § 1-2);
• local file prepared late: up to 240 daily rates (art. 56c § 3);
• no TPR, or a TPR with data that does not match the local file or reality: up to 720 daily rates (art. 80e § 1);
• TPR filed late: up to 240 daily rates (art. 80e § 2);
• a minor case is a fiscal petty offence, fined at 1/10 to 20 times the minimum wage: PLN 480.60 to PLN 96,120 in 2026 (art. 56c § 4, art. 80e § 3, art. 48 § 1).

CbC. Failing to file the CbC report or notification, or filing it incomplete or wrong: a monetary penalty of up to PLN 1,000,000 set by the Head of KAS (Dz.U. 2025 poz. 1379, art. 90-91).

Cross-border points

Corresponding adjustments. A Polish adjustment that taxes income already taxed abroad causes double taxation. Two routes:

• EU Arbitration Convention: a mutual agreement request to the Minister of Finance within 3 years of the first notice of the action that causes double taxation (Dz.U. 2023 poz. 948, art. 66(2)).
• EU dispute resolution directive procedure: a complaint within 3 years of the first notice (Dz.U. 2023 poz. 948, art. 11(1)), filed with each state concerned.
• Mutual agreement procedure under a tax treaty: the time limit is the one in that treaty; a late request is rejected (Dz.U. 2023 poz. 948, art. 72 to 78, art. 73(1)).

Domestic corresponding adjustment. Where the authority adjusts a Polish company's income under art. 11c and the other party is also Polish, that other party can apply to its own tax office to adjust its income to match (Dz.U. 2023 poz. 948, art. 79).

APAs (Dz.U. 2023 poz. 948, art. 81 to 105). The Head of KAS issues an APA on application by the Polish related party. Unilateral, bilateral and multilateral APAs exist. The fee is 1% of the transaction value in the period requested, within the floors and caps in the table; paid within 7 days of filing (art. 98). Covered transactions need no local file (CIT Act art. 11n(2)) and the authority cannot adjust income that follows the APA (art. 11c(6)).

Permanent establishments. Attribution of income to a PE is a controlled transaction (art. 11a(1)(6)). A Polish PE of a non-resident whose income a treaty gives only to the other state needs no local file (art. 11n(9)).

Tax havens. Any transaction with a party on the harmful tax competition list, related or not, above PLN 2,500,000 (financial) or PLN 500,000 (other) needs a local file that also explains the business reason and the expected benefits, tax benefits included (art. 11o, art. 11q(1a)). Neither safe harbour is available where the lender or service provider is in such a state.

Related rules in the CIT skill. The shifted-income tax (art. 24aa), CFC rules, minimum tax add-backs for related-party costs, the interest cap and withholding on related-party payments above PLN 2,000,000 all sit in pl-cit-corporate-tax.

Worked examples

Example 1: Related-party loan below the safe harbour, no local file

A Polish sp. z o.o. (calendar tax year, 19% CIT) lends PLN 15,000,000 to its Czech sister company on 2 January 2026 for 3 years at a fixed 2.00% a year, with no fees. It has no other related-party loans. It does not prepare a local file.

Safe harbour test. The lender's rate must be at least the base rate plus 2.0 points (M.P. 2025 poz. 1249). The client must look up the WIBOR 3M (or WIRON 3M or POLSTR 3M) fixing for the contract date. For this example we assume the base rate on that date was 4.00%, so the floor is 6.00%. At 2.00% the loan fails art. 11g(1)(1). Capital of PLN 15,000,000 is above the PLN 10,000,000 financial threshold, so a local file was due by 2 November 2027 (the end of October 2027, moved past the weekend and holiday) and was not prepared.

Adjustment. In an audit, the authority tests the rate under art. 11d. In this example it sets the arm's length rate at 6.00%, the same as the safe-harbour floor. That is the assumption here; the law does not require the authority to land there. Missing interest for 2026: PLN 15,000,000 × 4.00 points = PLN 600,000. CIT at 19%: PLN 114,000, plus late payment interest from the original due date.

Additional tax liability. The base is PLN 600,000, under PLN 15,000,000. Because no local file was submitted, the rate doubles to 20% (Tax Ordinance art. 58c § 1(3)): PLN 120,000. Had the file existed and been handed over, the rate would have been 10%: PLN 60,000. So the missing file costs PLN 60,000 extra, before the fiscal penal fine on the board members (up to 720 daily rates, KKS art. 56c § 1).

name: Related-party loan below the 2026 safe harbour, PLN 15m, no local file
inputs:
  loan: 15000000
  rate_charged: 2.00
  base_rate_assumed: 4.00
  lender_min_margin: 2.0
  cit_rate: 19
  extra_rate_basic: 10
  extra_rate_no_docs: 20
steps:
  - arms_length_rate: base_rate_assumed + lender_min_margin
  - interest_charged: pct(loan, rate_charged)
  - interest_arms_length: pct(loan, arms_length_rate)
  - adjustment: interest_arms_length - interest_charged
  - cit_on_adjustment: pct(adjustment, cit_rate)
  - additional_liability_with_docs: pct(adjustment, extra_rate_basic)
  - additional_liability_no_docs: pct(adjustment, extra_rate_no_docs)
  - cost_of_missing_file: additional_liability_no_docs - additional_liability_with_docs
  - total_no_docs: cit_on_adjustment + additional_liability_no_docs
expected:
  arms_length_rate: 6.00
  interest_charged: 300000.00
  interest_arms_length: 900000.00
  adjustment: 600000.00
  cit_on_adjustment: 114000.00
  additional_liability_with_docs: 60000.00
  additional_liability_no_docs: 120000.00
  cost_of_missing_file: 60000.00
  total_no_docs: 234000.00

Example 2: Does the company need a local file?

A Polish sp. z o.o., calendar year 2026, is 100% owned by a German parent. It is not a micro or small entrepreneur. Its 2026 related-party transactions, net of VAT, are:

• goods bought from the parent: PLN 12,400,000;
• goods sold to a Czech sister company: PLN 6,300,000;
• management services bought from the parent: PLN 1,850,000;
• IT services sold to a Dutch sister company: PLN 2,150,000;
• a loan taken from the parent: capital PLN 9,000,000, at a rate outside the safe harbour.

Test each homogeneous transaction against its own threshold, per side (art. 11k(2)-(3)). Purchases of goods (PLN 12.4m) exceed PLN 10m: local file. Sales of goods are a separate, revenue-side transaction (PLN 6.3m): no. Management services bought (PLN 1.85m) are under PLN 2m: no. IT services sold (PLN 2.15m) exceed PLN 2m: local file. The loan (PLN 9m capital) is under the PLN 10m financial threshold: no. So two transactions need a local file, by 2 November 2027, and the company files TPR-C by 30 November 2027 covering those two.

The edge case. If the parent also charged PLN 400,000 for IT support that, on the facts, is homogeneous with the management services, the two are added: PLN 2,250,000, over PLN 2m. Splitting one service across several invoices or contracts does not help (art. 11k(4)). Separately, if the group's consolidated revenue for 2025 exceeded PLN 200,000,000, the company must attach the master file by 31 December 2027.

name: Local file test by transaction type, calendar 2026
inputs:
  goods_bought: 12400000
  goods_sold: 6300000
  mgmt_services_bought: 1850000
  it_services_sold: 2150000
  loan_capital_taken: 9000000
  it_support_bought: 400000
  threshold_goods: 10000000
  threshold_financial: 10000000
  threshold_services: 2000000
steps:
  - lf_goods_bought: ceil(clamp(goods_bought - threshold_goods, 0, 1))
  - lf_goods_sold: ceil(clamp(goods_sold - threshold_goods, 0, 1))
  - lf_mgmt_services: ceil(clamp(mgmt_services_bought - threshold_services, 0, 1))
  - lf_it_services_sold: ceil(clamp(it_services_sold - threshold_services, 0, 1))
  - lf_loan: ceil(clamp(loan_capital_taken - threshold_financial, 0, 1))
  - transactions_needing_local_file: lf_goods_bought + lf_goods_sold + lf_mgmt_services + lf_it_services_sold + lf_loan
  - services_if_homogeneous: mgmt_services_bought + it_support_bought
  - lf_services_if_homogeneous: ceil(clamp(services_if_homogeneous - threshold_services, 0, 1))
expected:
  lf_goods_bought: 1
  lf_goods_sold: 0
  lf_mgmt_services: 0
  lf_it_services_sold: 1
  lf_loan: 0
  transactions_needing_local_file: 2
  services_if_homogeneous: 2250000
  lf_services_if_homogeneous: 1

Ask the client first

1. Who are the related parties, and through what: share percentages (direct and indirect), board control, family ties? Is any counterparty in a country on the harmful tax competition list?
2. For each transaction type in the tax year: value net of VAT, cost side or revenue side, and which services or goods could be one homogeneous transaction.
3. For each related-party loan, credit, bond or guarantee: capital, currency, contract date, rate and base, fees, term, and the total of all related-party loans given and taken.
4. Are all counterparties Polish? If so, did any of them have a tax loss in the year or use an art. 6 or special-zone exemption?
5. Group consolidated revenue in the prior financial year (master file at PLN 200m; CbC at PLN 3.25bn or EUR 750m), and is the company a micro or small entrepreneur?
6. Any APA, existing benchmark (and its date), past year-end adjustments, open audit or MAP?

Sources

Source	URL	Read on
CIT Act, consolidated text Dz.U. 2026 poz. 554 (art. 11a to 11t)	https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20260000554	2026-10-23
Act of 18 September 2026 amending the PIT and CIT Acts, Dz.U. 2026 poz. 1371 (TPR, art. 11e)	https://api.sejm.gov.pl/eli/acts/DU/2026/1371/text.pdf	2026-10-23
PIT Act, consolidated text Dz.U. 2026 poz. 592 (art. 23m to 23zf)	https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20260000592	2026-10-23
Tax Ordinance, consolidated text Dz.U. 2026 poz. 622 (art. 12 § 5, art. 58a to 58e); later amendments Dz.U. 2026 poz. 825, 846 and 1154 do not change art. 58a to 58e	https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20260000622	2026-10-23
Fiscal Penal Code, consolidated text Dz.U. 2025 poz. 633 (art. 23, 24, 48, 56c, 80e)	https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20250000633	2026-10-23
Public holidays act (ustawa o dniach wolnych od pracy), consolidated text Dz.U. 2025 poz. 296 (art. 1)	https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20250000296	2026-10-23
Minimum wage for 2026, Dz.U. 2025 poz. 1242	https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20250001242	2026-10-23
MF notice on base rates and margins for 2026, M.P. 2025 poz. 1249	https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WMP20250001249	2026-10-23
Act on resolving double taxation disputes and APAs, consolidated text Dz.U. 2023 poz. 948 (art. 11, 66, 72-79, 81-105)	https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20230000948	2026-10-23
Act on exchange of tax information, consolidated text Dz.U. 2025 poz. 1379 (art. 82 to 91, CbC)	https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20250001379	2026-10-23
Amending act Dz.U. 2026 poz. 347 (exchange of information act; art. 91 cross-references only)	https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20260000347	2026-10-23
MF regulation on transfer pricing documentation (CIT), consolidated text Dz.U. 2023 poz. 1783	https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20230001783	2026-10-23
MF regulation on the TPR (CIT), amendment Dz.U. 2025 poz. 1744	https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20250001744	2026-10-23
MF regulation listing harmful tax competition states (CIT), Dz.U. 2024 poz. 1928	https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20240001928	2026-10-23
podatki.gov.pl, Ceny transferowe (TPR-C(6), 2026 safe harbour notice)	https://www.podatki.gov.pl/ceny-transferowe/	2026-10-23

Not yet confirmed: the WIBOR 3M, WIRON 3M or POLSTR 3M fixing for any particular contract date (example 1 assumes 4.00%; take the actual fixing from the benchmark administrator); whether a calendar-2025 TPR filed after that date must still carry the repealed statement (the transitional rule in art. 4(1) covers only tax years straddling 1 January 2026); the TPR-C form version and regulation for tax year 2026 (not yet published); whether the Ministry of Finance accepts that Tax Ordinance art. 12 § 5 moves the local file preparation deadline (the text applies it to deadlines in tax law; no MF guidance read); the full list of low-value services in annex 6 to the CIT Act (not reproduced here); the detailed content requirements in the documentation regulation (not read in full); treaty-specific MAP time limits.

Contributed by Ryan Duguid.