A draft law significantly changing the Polish transfer pricing regulations was published on 16 July 2018. The draft law grants the tax authorities new tools for auditing and challenging related-party transactions, and changes the obligations imposed on taxpayers conducting such transactions.
The new regulations are intended to enhance the efficiency of tax audits and transparency of related-party transactions. The new rules are to apply as from 1 January 2019. However, taxpayers may apply the new regulations on transfer pricing documentation to tax years started after 31 December 2017.