On November 15, 2024 the President of Poland signed a new law that establishes a 15% global minimum tax for large corporate groups, that will enter into force starting from January 1, 2025. The law establishes rules to calculate effective tax rates and determine which corporate units will be subject to supplementary tax. Finance ministry estimates suggest around 7,000 entities in Poland fall under the law, though most will be unaffected as they already meet the tax requirements. The 15% minimum tax is part of a broader OECD agreement on global tax reform.
On September 4, 2024, the Polish Ministry of Finance updated its FAQs on domestic transfer pricing reporting obligations. Among the provided information, key topics include transfer pricing reporting (TPR) requirements, controlled transactions subject to TPR requirements, and the calculation methods of the transfer pricing amount. The updates further address the process for submitting corrections via TPR-C (5) forms, reporting after company dissolution, or following a takeover by a foreign entity.
In addition, the guidance explains TPR form types for general partnerships, criteria for micro or small entity status, and reporting transaction data using safe harbor simplifications.
Finally, the guidance notifies taxpayers with a tax year matching the calendar year to submit transfer pricing information for 2023 by November 30, 2024.