Transfer Pricing Under Scrutiny by Regulatory Authorities – Preparing for 2025 TP Obligations
Dear Sir or Madam,
The approaching deadlines for documenting and reporting transactions with related parties in 2025 provide a good opportunity to plan your transfer pricing work well in advance.
In practice, we observe that transfer pricing is increasingly becoming a focus of tax authorities’ attention as early as the preliminary review stage, as part of what is known as a “soft transfer pricing audit.” The National Revenue Administration (KAS), using data from sources such as TPR information, JPK files, and CBC reporting, can identify specific taxpayers to whom requests and inquiries are directed even before a formal audit begins. In this context, early verification of intra-group settlements can facilitate the identification of potential risks, the collection of necessary data, and the efficient fulfillment of compliance obligations regarding local documentation and TPR-C declarations.
Although the deadlines for the 2025 tax year (ending December 31, 2025) fall in October and November 2026, experience shows that to effectively prepare for these obligations, it is advisable to plan your actions now. Sometimes, analyzing the arm’s-length nature of intra-group transaction terms requires a longer-term commitment—both on your part and on the part of your headquarters and your advisor.
As part of our services, we can offer you comprehensive support in fulfilling your transfer pricing obligations for 2025, including, in particular, risk analysis, the preparation or updating of local and group documentation, the development of comparative analyses tailored to the specifics of your transactions, as well as support in preparing and filing TPR information and other required reports.
If you would like to plan your activities in this area well in advance or discuss your situation, we are at your disposal and encourage you to contact us.
KONTAKT
E: arkadiusz.zurawicki@pl.Andersen.com
T: +48 22 690 08 71
M: +48 508 092 989
E: piotr.sukienik@pl.Andersen.com
T: +48 32 731 68 50