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News / December 2019 Alert – Transfer Pricing – Important Deadlines!

December 2019 Alert – Transfer Pricing – Important Deadlines!


13.12.2019

December 2019 Alert – Transfer Pricing – Important Deadlines!

The closing of 2019 is approaching. Following numerous questions, we have summed up the most important deadlines for performing obligations to provide documents and reports by entities transacting with related parties.

Documentation Obligations

Documentation element

Deadline

Local file

End of 9th month from financial year end

Master file

End of 12th month from financial year end

Submission of documentation requested by tax authorities

Within 7 days from request being received

 

Reporting Obligations

 

Notably, the reporting obligations cover a new TP-R report (that replaces CIT-TP/ PIT-TP) being a modern system of reporting detailed information about transactions with related entities. The new TP-R transfer pricing reporting form will be filed electronically.

 

In TP-R, taxpayers will be obliged to indicate e.g. general financial information, transaction details and the outcome of benchmarking analyses. The report will be used to show among other things information about methods and prices used in settlements with related business partners, including detailed information about verification of the same, e.g. usage of internal or external comparative data about prices, expert valuations, determination of a range constituting the outcome of benchmarking analyses, or indication of the ratios obtained.

 

The table below sums up a schedule of reporting actions applicable to transfer pricing.

 

Document

Deadline

Statement on preparation of Local File

End of 9th month from financial year end

TP-R

End of 9th month from financial year end

CbC-P

End of 3rd month from financial year end

CbC-R

End of 12th month from financial year end

 

 

If you have any questions, please do not hesitate to contact me.

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