2020, the year in which taxpayers filed TPR forms for the first time, clearly showed the need for proper planning of the entire transfer pricing reporting process. In an effort to meet both market needs and tax administration requirements, we have developed the following action plan to streamline this year’s reporting process, with detailed guidelines for every step. We encourage you to read this and contact our experts for further assistance.
Due to the COVID-19 pandemic, the deadline for submission of the local file and TPR form for 2020 has been extended to 31 December 2021.
To help you avoid stress and the need for active repentance due to potential delays or errors, we offer structured company support. We encourage you to begin preparing your companies for fulfilling all transfer pricing obligations at the earliest opportunity.
Because of its volume and detailed questions, the TPR form can be complicated to complete in practice. At the same time, a well-filled TPR streamlines the preparation of the local file and even identifies previously unnoticed areas of risk. Therefore, the best way to start effective transfer pricing reporting, is by completing the TPR. Please note that for the purposes of 2020 reporting , it will be necessary to prepare for using the new version of the form published by the Ministry of Finance.
When preparing the 2019 TPR, you have probably updated yourself on the benchmarking studies or arm’s length compliance descriptions that need to be prepared. We will highlight all the important issues for attention and, if necessary, prepare a complete set of studies for you.
Once the benchmark studies or compliance descriptions have been produced, a Local File comprising a description of transactions plus the data already provided in the TPR and results of the benchmarking studies/compliance descriptions will need to be prepared. We will highlight all the important issues to pay attention to during this work and, if necessary, prepare a set of analyses for you.
In most cases this will be the final step/completion of the TP reporting process. All that remains to be done is submit the TPR form to the Head of the National Tax Administration and timely file the statement of preparation of the Local File and application of arm’s length prices (transfer pricing statement) with the competent tax office.
The best performing entities are obliged to prepare not only the TPR form and Local File including benchmarking studies and compliance descriptions, but also the Master File, group information (CbC-R report) and CbC-P notification. Although the deadline for full transfer pricing reporting is longer, it is advisable to fulfil this obligation as soon as possible.
