First such ruling in Poland

Tomasz Wilk

Katarzyna Olejniczak

On 26 May 2025, we secured the first ever private tax ruling in Poland where the authorities precisely explained how to quantify cash pool transactions for the purposes of transfer pricing documentation.

Why is it important?

• June is a time when many companies check if their transactions with related parties exceed reporting thresholds requiring them to prepare transfer pricing documentation.
• As a reminder, TP documentation needs be prepared by October 31st while the due date to file form TRP-C is November 30th.

If cash pooling and transfer pricing are topics that have just appeared on your agenda, you may want to understand how they are currently approached by tax authorities.

Please let us know if you wish us to share the details of the ruling or review your transactions.