Draft amendments to PIT/CIT – simplifications in transfer pricing
On January 13, 2026, the list of legislative work of the Chancellery of the Prime Minister included information about a planned draft amendment to the Personal Income Tax Act and the Corporate Income Tax Act. The draft is to concern, among other things, significant changes in the area of transfer pricing. Although it is still at an early stage of legislative work, its assumptions may significantly affect the way taxpayers fulfill their documentation and reporting obligations.
The most important planned changes in the area of transfer pricing will include:
Simplification of the rules for signing TPR information – forms are to be signed in accordance with the rules set out in the Tax Ordinance, which will enable them to be submitted by a representative;
Combining the declaration with local transfer pricing documentation, which may reduce the scope of separate formal obligations;
Further simplifications for micro and small entrepreneurs – in particular, the abolition of the obligation to disclose financial indicators reflecting the financial situation of these entities in the TPR;
Clarification of the rules for applying transfer pricing adjustments (so-called compensatory adjustments) between domestic entities, by removing interpretative doubts regarding the possibility of making such adjustments between entities based in Poland.
What does this mean for taxpayers?
The planned changes may translate into reduced formalities, greater organizational flexibility, and a lower risk of formal errors. However, it should be emphasized that these are only proposals at this stage – the final scope of the regulations will only be known after the legislative process has been completed.
We will monitor the progress of the work on an ongoing basis and keep you informed of any further significant changes.
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