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The COVID-19 pandemic ends but does support remain?

by Piotr Prokocki

On 01 July 2023, the “pandemic” in Poland will legally and officially come and end. Numerous support measures under the Anti-Covid Special Act will cease to apply. However, some of those solutions have been made permanent under law.

Interpretation Challenge

The challenge now is how to correctly interpret the regulations that came into force during the pandemic but now may seem unnecessary.

Transfer Pricing Problems

Officially revoking the pandemic in Poland will cause a great deal of confusion in terms of tax obligations. We have grown accustomed to the measures introduced under the so-called ‘crisis shield’ for more than three years. Officially revoking the pandemic will also mean shorter deadlines for drawing up transfer pricing documentation and filing TPR-C forms.

Poland’s Ministry of Finance plans to implement simplifications to transfer pricing regulations and introduce exemptions from documenting domestic transactions.

Time is Key

There is some confusion regarding the official date when certain support mechanisms will end. The Anti-crisis shield regulations state that two months after the pandemic officially ends, the support provisions regarding certificates of residence will cease to apply.

The challenge that lies ahead will be to correctly interpret and apply the norms contained in this act at this particular moment in time.


Published: July 2023

04 July 2023

Penteris