Transfer Pricing Reporting 2025 – approaching statutory deadline (1 December 2025)

• TPR-C – for corporate income tax (CIT) payers,
• TPR-P – for personal income tax (PIT) payers.

This information is submitted electronically only and concerns transactions carried out with related entities or entities from so-called tax havens.

Who signs the TPR form?

Pursuant to Article 11t(5) of the CIT Act and the relevant provision of the PIT Act, the TPR form is signed by:

• a natural person – if they are required to submit the information (TPR-P),
• a person authorized by a foreign entrepreneur – in the case of foreign branches,
• a member of the management board designated to sign (regardless of the method of representation) – in the case of CIT taxpayers with a multi-person management board,
• the manager of the entity – if the management board consists of one person.

Importantly, the TPR-C form is signed by only one designated member of the management board, usually on the basis of a management board resolution. The other members of the management board, even though they do not sign the information, are still responsible for its content.

Signing the form by a proxy

Exceptionally, the TPR may be signed by a professional representative, i.e.:

• a lawyer,
• a legal advisor,
• a tax advisor,
• a certified auditor.

It should be emphasized that a professional representative who signs a TPR-C or TPR-P bears full responsibility for the content of the information submitted, including the compliance of transfer prices with the arm's length principle.

Obligation to have a PESEL number

Every person signing the TPR-C or TPR-P form electronically must have a PESEL number. Without it, it is not possible to use a qualified electronic signature accepted by the Ministry of Finance systems.

If the signatory (e.g., a foreigner) does not have a PESEL number, it is necessary to obtain one:

• automatically – when registering for a stay of more than 30 days,
• upon request – in other cases.

After obtaining a PESEL number, a qualified electronic signature can be purchased from a certified provider (e.g., Szafir 2.0, Certum, Sigillum, EuroCert).

What if the formal requirements are not met?

The absence of any of the key formal elements (PESEL number, valid qualified signature containing this number, or correctly registered UPL-1 power of attorney) makes it technically impossible to submit the TPR form.
The Ministry of Finance system will reject the form at the stage of sending, which means that the transfer pricing information has not been effectively communicated to the tax authorities.

In practice, this means that the obligation to submit TPR-C or TPR-P has not been fulfilled at all, which qualifies as a serious violation of transfer pricing regulations.

This situation has real consequences, including:
 

• the risk of administrative sanctions,
• tax consequences,
• criminal and fiscal liability,
• increased risk of tax audits.

How can we help?

We provide comprehensive support in the following areas:

• preparing and completing TPR-C and TPR-P forms,
• obtaining PESEL numbers for board members and proxies from abroad,
• registration of UPL-1 powers of attorney,
• purchase and activation of a qualified signature,
• coordination of the process of signing and sending the TPR form,
• assisting with the submission of the form and ensuring confirmation of its successful submission in the e-Urząd Skarbowy system.

Feel free to contact – we will ensure that all obligations are fulfilled correctly and on time.