Transfer pricing – how to document loan granted in the given year and due in the subsequent one?

• Value of a transaction should be recalculated into PLN in line with exchange rate announced by the National Bank of Poland for last working day preceding the day of execution of the transaction or concluding the agreement.
• The notion of “a transaction” in the context of loans should be understood as the highest amount of loan principal due in a given tax year, resulting from an agreement or other documents.
• For loan granted and due for a period longer than a year the transaction should be declared in TPR form for each year in which its value exceeds the TP threshold, i.e. PLN 10M for financial transactions such as loans.
• Value of a transaction should be updated each year based on contractual provisions (e.g. repayment schedule) or other documents (bank accounts, accounting notes, account balance) and included in the TPR form for this particular year.
• The value of the transaction should be reported in TP documentation submitted for each year, until its repayment, provided that in a given tax year it exceeds the PLN 10M threshold.

Tax ruling no 0111-KDIB1-2.4010.612.2022.1.EJ

 If you have any questions, please do not hesitate to contact our experts:

Katarzyna Chajęcka
Tax Manager

Łukasz Bączyk
Head of Tax

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