Transfer pricing reporting – FAQs

This is the third edition of FAQs compiled by the Ministry of Finance. The updated edition deals with transfer pricing information returns to be filed using templates for a tax year beginning after 31 December 2020. 

 

The FAQs include the most frequent questions and answers about transfer pricing reporting. They have been compiled to make the reporting requirement facile and to ensure consistency of the presented data.  

 

 

1. The manner in which a transfer pricing information return is to be filed by limited partnerships that have become CIT taxpayers from 1 May 2021 has been clarified.  

 

A partnership that did not prepare financial statements as of 30 April 2021 should file a single transfer pricing information return for the entire 2021. If, however, the limited partnership prepared its financial statements as of 30 April 2021, the designated partner should file a transfer pricing information return for the period from 1 January 2021 to 30 April 2021. The next return (for the period from 1 May 2021 to 31 December 2021) should be filed by the limited partnership itself.

 

2. Reporting of transactions made by micro or small enterprises and transactions with tax havens  

 

A micro or small enterprise that is exempt from the obligation to include a benchmarking study or conformity analysis in its local file is not required to provide data on transfer pricing verification methods in its transfer pricing information return filed for 2021.

 

Similarly, the manner in which data are presented for transactions with tax heavens has been clarified.  There is no obligation to provide data on transfer pricing verification methods in the transfer pricing information return filed for 2021 with respect to transactions other than controlled transactions referred to in Article 11o of the CIT Act. 

 

3. It has been clarified that the TPR-C form may be signed using a qualified electronic signature that is certified by an entity designated by any EU member state.

 

The deadline for filing the transfer pricing information return for 2021 is 31 December 2022 (for taxpayers whose tax year is the same as the calendar year).

 

Dynamically changing tax legislation does not spare transfer pricing either. If you want to discuss your transfer pricing obligations or need support to comply with them – contact our experts.